GAO 

United States Government Accountability Office

Report to the Chairman, Committee on 

Agriculture, Nutrition and Forestry, 

U.S. Senate 

SCHOOL MEAL 

PROGRAMS 

Improved Reviews, 

Federal Guidance, and 

Data Collection 

Needed to Address 

Counting and Claiming 

Errors 

September 2009 

GAO-09-814 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

SCHOOL MEAL PROGRAMS 

Improved Reviews, Federal Guidance, and Data 

Collection Needed to Address Counting and Claiming

Highlights of GAO-09-814, a report to the Errors

Chairman, Committee on Agriculture, 

Nutrition and Forestry, U.S. Senate 

In fiscal year 2008, the National 

School Lunch Program and School 

Breakfast Program provided meals 

to 30.9 million and 10.5 million 

children, respectively. Recently, the 

U.S. Department of Agriculture 

(USDA) issued the first estimate of 

improper payments due to meal 

counting and claiming errors in 

these programs, which was 

approximately $860 million (8.6 

percent of federal program 

reimbursements) in school year 

2005-2006. These errors include: (1) 

cashier errors, such as those made 

in determining if a meal meets the 

federal menu planning and 

nutrition requirements (meal 

counting), and (2) aggregation 

errors made when officials count 

and total meals for federal 

reimbursement (meal claiming). 

GAO was asked to review (1) 

actions taken by states and school 

food authorities (SFA) to identify 

and address meal counting and 

claiming errors; and (2) actions 

taken by USDA to help states and 

SFAs identify and address meal 

counting and claiming errors. 

GAO’s steps included analyzing 

data on state administrative 

reviews of SFAs; surveying all 

states; conducting site visits; and 

interviewing federal, state, and SFA 

officials. 

What GAO Recommends

GAO recommends that the 

Secretary of Agriculture modify the 

requirements for state and SFA 

reviews and improve federal 

guidance and data collection. 

USDA agreed with GAO’s 

recommendations. 

Although states and SFAs conduct program integrity reviews of the school 

meal programs, gaps in federal requirements for these reviews limit their 

effectiveness at identifying meal counting and claiming errors. States and 

SFAs are generally not required to review the School Breakfast Program, and 

21 states reported through GAO’s survey that they do not review the breakfast 

program. However, USDA estimates that the percentage of meal counting and 

claiming errors is higher in the breakfast program than the lunch program. 

Further, some states reported that SFA reviews of the meal programs are 

ineffective at identifying and reducing errors, which may be due, in part, to the 

self-assessment design of these reviews. When state and SFA reviews identify 

errors, meal counting and claiming errors persist. For example, in several 

SFAs that GAO visited, the same errors were identified during consecutive 

reviews. States and SFAs identified multiple factors that hinder efforts to 

address these errors, such as staff turnover, inadequate training, and school 

policies that complicate meal service. 

Federally Required Reviews of Counting and Claiming in Meal Programs

Each year Each 5-year review cycle

Sources: GAO, Art Explosion (images).

State

SFA

SFA

SFA SFA

School

lunch

School

breakfast

No SFA on-site review required No state review required

If the state finds errors during its review of an SFA,

state conducts a follow-up review, including some on-site 

school reviews of both lunch and breakfast programs.

USDA has taken some actions to improve state reviews of SFAs, but it has not 

directly focused on oversight of meal counting and claiming. USDA recently 

provided new review forms and nationwide training to strengthen state 

reviews and also simplified the application process for state grants to conduct 

additional reviews of SFAs. However, USDA has not targeted its oversight 

efforts to identify or address meal counting and claiming errors. For example, 

USDA regional offices’ reviews of state administration of the school meal 

programs do not focus on these errors, and some regional officials could not 

provide information on the extent of these errors in the states they oversee. 

USDA also has not updated its meal counting and claiming manual since it 

was first issued in 1991. Further, while USDA collects annual data on findings 

from state reviews of SFAs, the agency has not used these data for oversight 

purposes or to assess risks associated with meal counting and claiming errors. 

View GAO-09-814 or key components.

For more information, contact Kay Brown at 

(202) 512-7215 or brownke@gao.gov. 
Page i GAO-09-814 

Contents 

Letter 1

Background 3 

States and SFAs Conduct Reviews, but Meal Counting and 

Claiming Errors Persist 10 

USDA Has Taken Some Actions to Improve State Monitoring, but 

Has Not Focused on Oversight of Meal Counting and Claiming 16 

Conclusions 21 

Recommendations for Executive Action 22 

Agency Comments and Our Evaluation 22 

Appendix I Objectives, Scope, and Methodology 24 

Appendix II GAO Contact and Staff Acknowledgments 28 

Tables 

Table 1: Federal Reimbursement per Meal and Average Daily 

Participation in the National School Lunch and School 

Breakfast Programs, School Year 2008-2009 4 

Table 2: APEC Estimates of Improper Payments Resulting from 

Meal Counting and Claiming Errors, during School Year 

2005-2006 9 

Figures 

Figure 1: Oversight and Monitoring Requirements for School Meal 

Programs 6 

Figure 2: School Meal Service Process and Potential Points of 

Error in the Meal Counting and Claiming Process 8 

Figure 3: Federally Required Reviews of Counting and Claiming 

Procedures in the School Meal Programs 11 

 School Meal Programs 
Abbreviations 

SFA school food authority 

FNS Food and Nutrition Service 

APEC Access, Participation, Eligibility, and Certification Study 

USDA U.S. Department of Agriculture 

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

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Page ii GAO-09-814 School Meal Programs
Page 1 GAO-09-814 

United States Government Accountability Office

Washington, DC 20548 

 

September 9, 2009 

The Honorable Tom Harkin 

Chairman 

Committee on Agriculture, 

 Nutrition and Forestry 

United States Senate 

Dear Mr. Chairman: 

The National School Lunch Program and School Breakfast Program had a 

combined fiscal year 2008 budget of $10.5 billion and provided lunches 

and breakfasts to more than 30.9 million and 10.5 million children, 

respectively. These programs are administered by the U.S. Department of 

Agriculture (USDA) through state agencies that, in turn, oversee local 

school food authorities (SFA). SFAs serve meals to children in schools and 

are responsible for fulfilling federal program requirements, such as 

accurately claiming meals for federal reimbursement and preparing meals 

that meet specific menu planning and nutritional requirements. To comply 

with federal requirements imposed by the Improper Payments Information 

Act of 2002, USDA released a study in 2007 estimating that $860 million in 

improper payments (8.6 percent of federal program reimbursements) 

resulted from meal counting and claiming errors in the school meal 

programs during school year 2005-2006. These errors include: (1) cashier 

errors, such as those made in determining if a meal meets the federal 

menu planning and nutritional requirements (meal counting), and (2) 

aggregation errors made when officials count and total meals for 

reimbursement (meal claiming). 

Because the USDA study was the first national study to document meal 

counting and claiming errors, there is now increased interest in how these 

errors are being addressed. The importance of taking action to reduce 

these errors and ensure that program funds are being used as effectively as 

possible may be particularly heightened if program participation continues 

to increase in the current economic environment. Based on your request, 

we conducted a study reviewing (1) state and SFA actions taken to 

identify and address meal counting and claiming errors, and (2) USDA 

actions taken to help states and SFAs identify and address meal counting 

and claiming errors. 

To address these objectives, we reviewed relevant federal laws, 

regulations, and agency guidance, as well as federal data on states’ 

 School Meal Programs 
 

administrative reviews of the school lunch program. We also interviewed 

USDA Food and Nutrition Service (FNS) officials, both from headquarters 

and all seven of its regional offices, as FNS oversees the school meal 

programs. In addition, we used multiple methods to gather information on 

state and SFA actions. First, we administered a Web-based survey of state 

child nutrition program directors in all 50 states and the District of 

Columbia between February and March 2009,1

 to which all state directors 

responded. While we did not validate specific information that directors 

reported through our survey, we determined that the data were sufficiently 

reliable for the purposes of this report. Second, we conducted site visits to 

at least one state in six of the seven FNS regions.2

 States selected provided 

geographic variation and had both high levels of school meal errors found 

during state administrative reviews and relatively high percentages of 

students eligible for free and reduced price meals. We visited one state 

(California, Illinois, Massachusetts, Mississippi, and Texas) in five of the 

regions, and in the Mid Atlantic Region, we visited both Washington, D.C. 

and Maryland. During each site visit, we interviewed state-level child 

nutrition program directors, as well as officials from two to three SFAs 

that either had experienced significant meal counting and claiming errors 

or had systems in place that state officials considered to be effective at 

identifying and reducing such errors. For each SFA interviewed, we also 

reviewed recent state monitoring findings on meal counting and claiming 

errors and observed school meal procedures in one or more schools. We 

cannot generalize our findings beyond the SFAs we visited. 

We conducted this performance audit from August 2008 through 

September 2009 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. See appendix I for 

additional information about our methodology. 

 

1

In two states, the school meal programs are overseen by two different state entities; 

therefore, we surveyed both officials in those states, for a total of 53 child nutrition 

program directors. 

2

We chose not to visit a state in the Mountain Plains Region because those states, on 

average, had the lowest level of participation in the school meal programs. 

Page 2 GAO-09-814 School Meal Programs
 

The school lunch and breakfast programs are overseen and administered 

by USDA through FNS, state agencies, and local SFAs. FNS sets 

nationwide eligibility and program administration criteria and provides 

reimbursements to states for each meal served that meets federal menu 

planning and nutrition requirements and is served to an eligible student. 

FNS also provides states with commodities based on the number of 

reimbursable lunches served. States have written agreements with SFAs to 

administer the meal programs, provide federal reimbursements to SFAs, 

and oversee SFA compliance with program requirements. SFAs—

nonprofit entities responsible for local administration of the school meal 

programs—plan, prepare, and serve meals to students in schools.3

Background 

SFAs determine the price they charge for school meals, but some children 

are eligible to receive free or reduced price meals. Specifically, children 

are eligible for free meals if their families have incomes at or below 130 

percent of the federal poverty guidelines and reduced price meals if their 

families have incomes between 130 and 185 percent of the federal poverty 

guidelines. SFAs can charge a maximum of $0.40 for a reduced price lunch 

and $0.30 for a reduced price breakfast. Children who are not eligible for 

free or reduced price meals pay the entire price charged by the SFA for the 

meal. 

SFAs receive federal reimbursements for all meals served to eligible 

students that meet menu planning and nutritional requirements, regardless 

of whether children pay for the meals or receive them for free. To receive 

federal reimbursements for meals, SFAs coordinate with schools to 

process an individual household application for most children applying for 

the free and reduced price programs4

 and verify eligibility for at least a 

sample of households that apply. SFAs also must keep daily track of meals 

provided. The amount of federal reimbursement that SFAs receive for 

each meal provided to a child is based on the eligibility category of the 

child and the meal program. (See table 1.) 

 

3

SFAs administer the meal programs in one or more schools. 

4

In some cases, SFAs are not required to process an application. For example, children 

from households that participate in the Supplemental Nutrition Assistance Program, 

Temporary Assistance for Needy Families, or Food Distribution Program on Indian 

Reservations are categorically eligible to receive free school meals and their families may 

not have to complete an application. 

Page 3 GAO-09-814 School Meal Programs
 

Table 1: Federal Reimbursement per Meal and Average Daily Participation in the 

National School Lunch and School Breakfast Programs, School Year 2008-2009 

Lunch program Breakfast program 

Eligibility 

category 

Federal 

reimbursement 

per meala

Average 

children 

served per 

dayb

Federal 

reimbursement 

per meala

Average 

children 

served per 

dayb

Free $2.57 15,900,000 $1.40 8,100,000

Reduced 

price 

2.17 3,100,000 1.10 1,100,000

Paid 0.24 11,300,000 0.25 2,000,000

Source: USDA. 

a

These are the basic cash reimbursement levels for school year 2008-2009. Higher federal 

reimbursement rates apply for Alaska and Hawaii, and for schools with high percentages of lowincome students. 

b

Data for May 2009. Participation data in table are approximate. 

To be eligible for federal reimbursement, meals served by SFAs must 

adhere to the Dietary Guidelines for Americans, which include limits on 

total fat and saturated fat and call for diets moderate in sodium. The meals 

must also meet standards for the recommended daily allowances of 

calories, as well as nutrients such as protein, calcium, iron, and vitamins A 

and C.5

 There are five federally approved food- or nutrient-based menu 

planning approaches for school meals. For example, under the traditional 

food-based menu planning approach, SFAs must offer five food items from 

four food components—meat/meat alternate, vegetables or fruits, 

grains/breads, and milk—for a lunch to qualify as reimbursable. SFAs 

choose the specific foods served and how they are prepared and 

presented. Under the nutrient standard menu planning approach, SFAs use 

a computer-based menu planning system that uses approved software to 

automatically analyze the specific nutrient content of planned menu items. 

Oversight and Monitoring 

in the School Meal 

Programs 

USDA policies and regulations establish an oversight and monitoring 

framework for school meal programs to help ensure accurate meal 

counting and claiming. (See fig. 1.) Specifically, regulations require data on 

meals served that qualify for federal reimbursement to be recorded at the 

point of service in schools and reported from SFAs to states, and states to 

 

5

Compliance with the standards is determined by averaging the nutritional content of the 

meals offered over a school week. 

Page 4 GAO-09-814 School Meal Programs
 

FNS. Both SFAs and states are required to regularly check meal counts to 

assess their reliability and reconcile any incorrect counts before 

submitting meal claim data for federal reimbursement. Federal regulations 

also require FNS, state agencies, and SFAs to conduct reviews of the 

school meal programs. FNS regions must conduct management 

evaluations of each state’s administration of the school meal programs and 

share evaluation findings with the state.6

 Through the coordinated review 

effort, states are required to conduct reviews of each SFA’s administration 

of the lunch program at least once during each 5-year review cycle7

 and 

share review findings with the SFA and FNS. At the local level, SFAs are 

required to conduct annual on-site reviews of the meal counting and 

claiming procedures in each school participating in the lunch program. 

 

6

Beginning with fiscal year 2009, each FNS region conducts state risk assessments to 

determine those that will receive a management evaluation in the current year. Previously, 

each region was required to conduct a management evaluation of all of its states within a 3-

year cycle. According to FNS officials, each management evaluation report is also shared 

with and reviewed by FNS headquarters staff. 

7

State reviews cover the full scope of SFA administration of the lunch program, including 

procedures related to certifying children as eligible for free and reduced price meals, meal 

counting and claiming, and monitoring schools. 

Page 5 GAO-09-814 School Meal Programs
 

Figure 1: Oversight and Monitoring Requirements for School Meal Programs 

USDA headquarters

Conduct reviews Submit meal 

claim data

States

USDA regional offices

SFA SFA SFA

Sources: GAO, Art Explosion (images).

The school meal programs’ oversight and monitoring requirements are 

part of their internal controls, which are an integral component of 

management. Internal control is not one event, but a series of actions and 

activities that occur on an ongoing basis. Effective internal controls 

include creating an organizational culture that promotes accountability 

and the reduction of error, analyzing program operations to identify areas 

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

address the identified risks, and monitoring the results and 

communicating the lessons learned to support further improvement.8

 

8

For more information on internal control, see GAO, Standards for Internal Control in the 

Federal Government, GAO/AIMD-00-21.3 (Washington, D.C.: November 1999). 

Page 6 GAO-09-814 School Meal Programs
 

To comply with the Improper Payments Information Act of 2002,9 in 

November 2007 USDA released the “Access, Participation, Eligibility, and 

Certification Study” (APEC),10 which provided the first national measure 

of improper payments in the school meal programs.11 APEC estimated th

approximately $860 million in improper payments occurred in the school 

lunch and breakfast programs due to meal counting and claiming errors 

during school year 2005-2006.

School Meal Counting and 

Claiming Errors 

at 

 

12 Meal counting, or cashier, errors occur 

when 

• a student’s specific meal selection does not meet the menu planning and 

nutritional requirements of a reimbursable meal, 

• the SFA’s planned meal components do not meet the menu planning and 

nutritional requirements of a reimbursable meal, or 

• a cashier incorrectly records the student’s categorical eligibility (i.e., free, 

reduced price, or paid). 

Meal claiming, or aggregation, errors generally occur because data on 

meals served are compiled and totaled by several different entities before 

they are submitted to FNS as a meal claim for reimbursement. Specifically, 

aggregation errors occur when 

• the daily meal count totals from the school cafeteria cashiers or points of 

sale are not summed correctly, 

9

Pub. L. No. 107-300, 116 Stat. 2350 (Nov. 26, 2002). 

10USDA, FNS, Office of Research, Nutrition and Analysis, “NSLP/SBP Access, Participation, 

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

Study Findings,” by Michael Ponza, et al. Project Officer: John R. Endahl (Alexandria, Va.: 

2007). 

11The Improper Payments Information Act defines an improper payment as any payment 

that should not have been made or was made in an incorrect amount (including 

overpayments and underpayments) under statutory, contractual, administrative, or other 

legally applicable requirements. 

12This estimate includes both overpayments in which the SFA receives more in federal 

reimbursements than it should, as well as underpayments in which the SFA receives less in 

federal reimbursements than it should. Because the method used to calculate improper 

payments in APEC did not eliminate offsetting errors that might occur, such as an 

overpayment and underpayment to the same SFA, this estimate should be considered the 

maximum amount of improper payments due to meal counting and claiming errors. 

Page 7 GAO-09-814 School Meal Programs
 

• school meal count totals are incorrectly reported to or recorded by the 

SFA, or 

• school meal count totals are incorrectly reported from the SFA to the 

state. 

Figure 2: School Meal Service Process and Potential Points of Error in the Meal 

Counting and Claiming Process 

Note: Actions taken before meal service may also cause meal counting errors. Specifically, errors 

occur when the SFA’s planned meal components do not meet the menu planning and nutritional 

requirements of a reimbursable meal. 

APEC found that a substantial source of meal counting and claiming errors 

were cashier errors, particularly for the breakfast program. Concerning 

aggregation, APEC found that school to SFA meal count reports were the 

most likely to be erroneous. (See table 2.) However, when this type of 

aggregation error occurred, APEC found it was typically the case that SFAreported meal counts were larger than those reported by the school, which 

resulted in overpayments to the SFA. APEC found that both cashier errors 

and aggregation errors between the school and SFA were concentrated in 

a small number of schools that had high error rates. 

0.00

Counting meals (during meal service) Claiming meals (after meal service)

Cashier

Determines whether meal 

includes all of the planned 

menu components

Determines the student’s

categorical eligibility (free, 

reduced price, or paid) 

After a meal, school 

staff totals meal counts, 

sometimes from 

multiple cashier lines

Daily or weekly, school 

totals meal counts and 

submits them to SFA

SFA totals all schools’

meal counts monthly 

and submits them to 

state for reimbursement

Sources: GAO, Art Explosion (images).

School

SFA

State

Page 8 GAO-09-814 School Meal Programs
 

Table 2: APEC Estimates of Improper Payments Resulting from Meal Counting and 

Claiming Errors, during School Year 2005-2006 

(Dollars in millions) 

Lunch program Breakfast program 

Federal 

dollars 

Percentage 

of federal 

funds 

Federal 

dollars 

Percentage 

of federal 

funds

Total federal program 

reimbursements 

$8,060 100 $1,940 100

Total meal counting & claiming 

improper payments (gross) 

 555 6.9 306 15.8

• Cashier/counting error 248 3.1 189 9.8

• Aggregation/claiming error 307 3.8 117 6.0

• School points of sale 

to school total 

26 <1 5 <1

• School to SFA 163 2 77 4

• SFA to state 118 1.5 35 1.8

Source: GAO analysis of APEC data. 

In addition to estimating meal counting and claiming errors, APEC also 

estimated that approximately $940 million in improper payments occurred 

in the school meal programs due to certification errors during school year 

2005-2006. Certification error occurs when students are certified to receive 

a level of free or reduced price meal benefits for which they are not 

eligible or are erroneously denied benefits for which they are eligible. 

Prior to APEC, the USDA Inspector General’s office conducted reviews of 

the school meal programs in various school districts nationwide from 2002 

to 2007. These reviews often found meal counting and claiming errors in 

the districts, which resulted in overpayments of federal funds. The reviews 

also frequently cited deficiencies in internal controls, such as omitted edit 

checks on meal claims and missing records of meals served, as causes of 

erroneous meal claims. (For more information on the reports reviewed, 

see app. I.) 

Page 9 GAO-09-814 School Meal Programs
 

States and SFAs 

Conduct Reviews, but 

Meal Counting and 

Claiming Errors 

Persist 

Gaps in State and SFA 

Review Requirements 

Limit Their Effectiveness 

Although states conduct program integrity reviews of the meal programs, 

oversight of the breakfast program is limited. Through the coordinated 

review effort,13 states are required to assess meal counting and claiming 

procedures used in schools when they review each SFA’s administration 

of the lunch program during the 5-year review cycle. However, only select 

schools in each SFA are reviewed.14 While all states reported through our 

survey that they conduct these reviews, 21 states reported that they do not 

include the breakfast program in reviews. Although APEC estimated that 

the percentage of errors in the breakfast program was more than double 

the percentage of errors in the lunch program, states are not required to 

review this program (see fig. 3). States, however, are required to review 

the School Breakfast Program during follow-up reviews.15 Further, states 

that include the breakfast program in their reviews do not always 

 

13The coordinated review effort for state administrative reviews of the school lunch 

program was implemented in 1992. At a minimum, states must conduct an administrative 

review of each SFA providing the lunch program in the state once during each 5-year 

coordinated review cycle provided that each SFA is reviewed at least once every 6 years. 

The current 5-year review cycle extends from July 1, 2008, to June 30, 2013. 

14As part of each review, the state is required to conduct a minimum number of on-site 

reviews of the SFA’s schools to assess meal counting and claiming procedures. States 

select schools receiving on-site reviews based on several criteria, including the number of 

schools in the SFA. 

15If an SFA’s critical area violations of lunch program requirements exceed federally 

defined thresholds, the state may be required to conduct a follow-up review. Specifically, 

states are required to conduct follow-up reviews of all large school SFAs (those with 

enrollments of 40,000 children or more) and at least 25 percent of small school SFAs with 

violations that exceed these thresholds. 

In addition, federal regulations for the School Breakfast Program direct states to provide 

program assistance, in part by providing personnel to monitor performance and visit 

participating schools to ensure compliance with program regulations. However, the 

regulations do not specify how to conduct these activities. In contrast, regulations for the 

National School Lunch Program provide specific monitoring requirements through the 

coordinated review effort. 

Page 10 GAO-09-814 School Meal Programs
 

systematically review that program. For example, officials in one state 

reported that they review the breakfast program whenever the 

administrative review of the SFA will take more than 1 day. 

Figure 3: Federally Required Reviews of Counting and Claiming Procedures in the School Meal Programs 

reviews each school, on-site

Each year Each 5-year review cycle

Sources: GAO, Art Explosion (images).

SFA State

SFA SFA SFA

School

lunch

School

breakfast

No SFA on-site 

review required

No state review 

required

reviews each SFA, including some schools, 

on-site

State

SFA

conducts a follow-up review, 

including some on-site school 

reviews of both lunch and 

breakfast programs

If the state finds

errors during its

review of an SFA

Some state officials also reported concerns about the extent to which 

required SFA on-site reviews effectively identify meal counting and 

claiming errors. Specifically, SFAs evaluate whether schools’ counting and 

claiming procedures comply with program requirements during their 

annual reviews of schools.16 However, like state reviews, SFAs are not 

required to review the breakfast program (see fig. 3). Nine states reported 

through our survey that SFA reviews were slightly or not at all effective in 

identifying and reducing meal counting and claiming errors. An additional 

21 states reported that these reviews were moderately effective at 

 

16For schools found to have errors, SFAs are required to assess corrective actions and 

conduct follow-up reviews within 45 days to ensure compliance issues have been 

sufficiently addressed. 

Page 11 GAO-09-814 School Meal Programs
 

achieving this goal. Although almost all states reported that they provide 

support to SFAs on completing annual on-site reviews, such as providing a 

form to document reviews, states also reported some factors that impede 

the quality of these reviews. For example, 20 states reported through our 

survey that some SFA reviewers lack the knowledge necessary to properly 

evaluate the program or consider on-site reviews to be a paperwork 

exercise instead of a monitoring tool.17

SFA on-site reviews are designed as self-assessments, and a few states 

reported through our survey that it is difficult for SFAs to review their own 

schools in an objective manner. At one large SFA we visited that serves 

over 100 schools, SFA reviews of schools were conducted, but the 

reviewers did not identify an issue causing erroneous meal claims that was 

identified in the state review completed shortly thereafter. The state 

determined that the resulting erroneous meal claims found during its 

reviews of the SFA totaled over $150,000. Officials from a small SFA we 

visited that serves six schools said they believe their on-site reviews are 

effective at identifying errors, but they also acknowledged that the 

problems identified through the most recent state administrative review 

had not been found during their on-site reviews. Specifically, the state 

review found that this SFA had submitted erroneous meal claims resulting 

in its receipt of a $6,200 overpayment of federal program funds. The 

“Standards for Internal Control in the Federal Government” states that key 

duties or responsibilities should be divided among different people to 

reduce the risk of error. However, the evidence obtained from some of the 

SFAs we visited suggests the self-assessment design of on-site reviews 

may be limiting their effectiveness. 

Multiple Factors 

Contribute to Persistent 

Meal Counting and 

Claiming Errors 

When state and SFA reviews identify meal counting and claiming errors, 

these problems are not always resolved. Several of the SFAs we visited 

had the same errors identified during consecutive state and SFA reviews. 

During successive reviews in two of the SFAs we visited, cashiers were 

counting meals that did not meet federal requirements to be reimbursable. 

 

17In a separate review of meal counting and claiming by food service management 

companies working with SFAs to administer the school meal programs, we similarly found 

that some state officials questioned the effectiveness of SFA annual on-site reviews either 

because the reviewers were not qualified to conduct them effectively or because the 

reviewers did not view the annual on-site review as a monitoring opportunity. For this 

review, we interviewed officials from 19 states in the Mid-Atlantic, Midwest, and Northeast 

regions. See GAO, Meal Counting and Claiming by Food Service Management Companies 

in the School Meal Programs, GAO-09-156R (Washington, D.C.: Jan. 30, 2009). 

Page 12 GAO-09-814 School Meal Programs
 

For example, one SFA director found that three of the five cashiers in a 

school he was observing could not accurately identify the meal 

components that made up a reimbursable meal on the day of his on-site 

review, which was an error identified in the previous state administrative 

review. In two other SFAs, successive state reviews found claiming errors, 

which impacted the accuracy of meal claims. In all of these SFAs, after 

errors were found during the first review, corrective actions were 

prescribed that should have modified procedures to reduce errors.18 One 

SFA official told us that the repeat meal counting and claiming errors 

found in multiple state administrative reviews did not surprise him, as he 

had found similar errors during his annual on-site reviews, and the 

corrective actions his SFA took had been ineffective. 

States and SFAs identified several factors that hinder efforts to address 

meal counting and claiming errors. 

• Staff turnover: Nineteen states reported through our survey that staff 

turnover affects whether corrective actions permanently resolve errors. In 

addition, some state and SFA officials we interviewed told us that the 

frequency of SFA staff turnover results in a continued need to retrain staff 

on accurate procedures. 

• Competing demands: Over 40 percent of states reported through our 

survey that competing demands for cafeteria staff greatly or moderately 

hinder efforts to address meal counting and claiming errors. During our 

site visits, several state officials told us that cafeteria staff sometimes 

fulfill additional roles in schools, such as bus drivers or school secretaries, 

which can affect their ability to focus on fulfilling meal program 

requirements and modifying procedures to address errors. 

• Inadequate training: Some state and SFA officials said that inadequate 

training of SFA staff affects whether corrective actions resolve errors. 

While nearly all the SFAs we interviewed conduct training, some officials 

acknowledged that certain aspects of the school meal programs are 

sufficiently complicated that more training may be needed. Specifically, 

state administrative reviews of almost half the SFAs we visited found 

cafeteria staff incorrectly identifying reimbursable meals, and some state 

 

18During administrative reviews, if states determine that SFAs have not complied with 

program requirements, they are required to prescribe corrective actions, such as training, 

technical assistance, or recalculation of data. SFAs are required to report to states when 

corrective actions are completed. 

Page 13 GAO-09-814 School Meal Programs
 

officials we interviewed told us that different types of menu planning 

approaches can make this difficult for cafeteria staff.19 In addition, officials 

from four SFAs we visited told us that adding options to menus can make 

it more difficult for staff to identify a reimbursable meal. While the five 

menu planning approaches offer SFAs flexibility and providing several 

menu options may appeal to students, both of these factors complicate 

cashier efforts to accurately count reimbursable meals. 

• Point of sale systems: Some state and SFA officials we interviewed told 

us that the lack of an automated point of sale system in schools, through 

which cafeteria staff count meals served to children each day, hinders SFA 

efforts to address errors. Specifically, most state officials we interviewed 

indicated that having an automated point of sale system, or computer, for 

cashiers to identify children receiving meals, their eligibility for free or 

reduced price meals, and components on each child’s tray reduces the 

likelihood of errors. However, some SFAs said that resource constraints 

had prohibited them from purchasing these automated systems. While 

these systems may help reduce counting and claiming errors, half of the 

state officials we interviewed indicated that point of sale systems can 

contribute to errors when staff are not properly trained on how to use the 

system or the system software is not properly set up or tested. 

• Specific school policies: According to some SFA officials we 

interviewed, certain types of school policies can complicate cashier efforts 

to address meal counting problems. For example, some schools have 

policies that children will be served a meal regardless of their ability to 

pay. While such children receive a meal for free, they are not necessarily 

eligible for a free reimbursable meal based on family income. However, 

cashiers sometimes do not understand this distinction and count these as 

free reimbursable meals. Similarly, school policies that shorten school 

meal periods sometimes also contribute to cashier errors. A few state and 

SFA officials reported that while shorter meal periods increase academic 

instruction time, they also require cafeteria workers to provide meals to 

children more quickly, which can result in meal counting errors. In one 

review of an SFA we visited, the state reported that the rapid flow of 

students through the lunch lines was affecting the ability of cafeteria staff 

to assess whether all meals were complete. 

 

19APEC found that schools using a food-based menu planning approach had higher levels of 

cashier error than those that used other approaches, such as a nutrient standard menu 

planning approach. 

Page 14 GAO-09-814 School Meal Programs
 

• Ineffective school support: A lack of effective support from school staff 

was also reported by some SFAs as hindering efforts to permanently 

address meal counting and claiming errors. For example, one SFA official 

reported that a school official had changed the school’s counting and 

claiming system without consulting the SFA, which caused related errors. 

Officials from another SFA reported that they now employ most of the 

cafeteria staff in their schools because of the difficulty in getting changes 

made to meal service when school administrators employ these staff.20

During our site visits, we observed that the involvement of school staff, 

such as teachers, in meal service may affect errors. For example, in a few 

schools, meals served were counted by teachers in their classrooms 

instead of by staff in the cafeteria. In at least one of these schools, the 

counting procedure used by the teacher produced errors. In another 

school, a teacher provided all of her students’ identification cards to the 

cashier to indicate the students were eating lunch, but not all of those 

students were present that day—a procedural error that had been cited on 

a previous state review of this school. 

In addition, states’ infrequent use of certain program sanctions may also 

affect the priority SFAs give to addressing errors.21 While federal 

regulations require states to withhold meal program funds from SFAs for 

certain program violations, such as not completing prescribed corrective 

actions within agreed-upon time frames, administrative review data 

suggests that states withhold funds from few of the SFAs reviewed. 

Further, only four states reported through our survey that they had 

terminated an SFA from the school meal programs during the past 5 years 

because of meal counting or claiming errors.22 States likely consider 

multiple factors when deciding whether to use the federally allowed 

sanctions, such as the fiscal effect of withholding program funds on an 

SFA’s ability to provide meals to children, which may influence the 

frequency with which these are used. An official in one of the states we 

 

20SFAs do not always employ all of the staff who serve meals in schools. For example, 

teachers and other staff employed by school districts sometimes assist with meal service, 

including meal counting procedures. 

21During a follow-up administrative review, if the state determines that the SFA has not 

sufficiently corrected compliance issues, the state must withhold program funds until the 

SFA takes appropriate corrective actions. In serious cases of noncompliance, states have 

the discretion to terminate an SFA’s participation in the meal programs. 

22While one state reported terminating 10 SFAs, the other three states had terminated 1 SFA 

each. 

Page 15 GAO-09-814 School Meal Programs
 

visited said that his state prefers to work with SFAs to correct problems 

rather than terminate their participation in the meal programs. 

Many state officials do not believe that meal counting and claiming errors 

are significant, and these views may also affect efforts to address errors. 

According to the “Standards for Internal Control in the Federal 

Government,” the attitude and philosophy of management toward 

monitoring can have a profound effect on internal control. Although the 

APEC study found that meal counting and claiming errors were a 

significant source of improper payments in the school meal programs, 

state officials reported through our survey that they are rare. Specifically, 

34 states reported that meal claiming errors and 26 states reported that 

meal counting errors were seldom or never a problem within their SFAs. 

Further, one state official reported through our survey that this is a 

problem made up by USDA, as very few of these errors occur. However, 

state administrative review data suggests that meal counting and claiming 

errors have occurred in SFAs and schools nationwide. 

USDA Has Taken 

Some Actions to 

Improve State 

Monitoring, but Has 

Not Focused on 

Oversight of Meal 

Counting and 

Claiming 

USDA Recently Took Some 

Steps to Update, 

Strengthen, and Increase 

the Number of State 

Reviews 

In 2008, USDA released an updated form for states to use when conducting 

state administrative reviews through the coordinated review effort. 

According to USDA officials, the form was updated to address recent 

legislative and regulatory changes. The updates to the form included new 

questions related to certification and food safety, as well as some minor 

revisions to existing questions. For example, some of these revisions 

Page 16 GAO-09-814 School Meal Programs
 

added descriptive details related to the review of meal counting and 

claiming procedures. Also in 2008, USDA held related training that focused 

on the entire review process, including meal counting and claiming 

procedures, as well as particular areas that states had reported a need for 

additional training. USDA officials reported that reviewers from almost all 

states attended the training. Officials also reported that they are 

developing updated policy guidance for state administrative reviews, 

which will address both the new form and issues that have arisen since the 

last guidance was published in 1993. 

In another effort to strengthen the state administrative review process, 

USDA issued a memo in March 2008 that directed states to stop 

conducting practice reviews. Prior to issuing the memo, USDA officials 

became aware that some states were conducting practice reviews to 

reduce documented findings and required corrective actions. USDA’s 

memo stated that because practice reviews only temporarily reduce the 

likelihood of documented review findings, they undermine the integrity of 

the review process, diminish the importance of adhering to school meal 

program requirements, and are in direct conflict with federal review 

requirements. While the memo indicated that states should stop 

conducting practice reviews immediately, USDA officials said they do not 

know if all states have stopped this activity. 

Since fiscal year 2005, USDA has also provided annual grants to, in part, 

support state efforts to conduct additional reviews of meal counting and 

claiming and certification procedures in SFAs that have a high level of, or 

high risk for, administrative error in the school meal programs.23 In an 

effort to increase state use of these Administrative Reviews and Training 

Grants, USDA simplified the application process for the fiscal year 2009 

cycle, through which $16 million in grant funds were available. 

Specifically, the streamlined application requirements allowed states to 

submit a 1-page form to apply for up to $3,500 per SFA review, as well as 

submit requests for multiple SFA reviews on one form. In May 2009, USDA 

awarded approximately $300,000 total in administrative review grants to 

 

23The Child Nutrition and WIC Reauthorization Act of 2004 (Pub. L. No. 108-265) 

established a requirement that states conduct additional administrative reviews of certain 

high-risk SFAs and provided funding for states to conduct these reviews and train SFAs. 

These reviews are in addition to the requirement that states review all SFAs within each 

5-year cycle. 

Page 17 GAO-09-814 School Meal Programs
 

the eight states that applied for them, a number equal to the greatest 

number of states that had received these grants in prior years.24

Other recent USDA efforts may also help identify and address meal 

counting and claiming errors in the school meal programs. In 2007 and 

2008, USDA issued updated guidance on complying with federal menu 

planning and nutritional requirements for school meals, as part of the 

School Meals Initiative. Through this initiative, states are required to 

conduct reviews of SFAs to determine their compliance with these 

requirements.25 USDA officials reported that these reviews can be helpful 

in identifying and addressing meal counting errors, as reviewers observe 

children’s meals at the point of sale. In addition, USDA is currently 

working with the National Food Service Management Institute26 to develop 

additional technical assistance materials for SFAs related to planning and 

recognizing reimbursable meals. These materials are intended to help food 

service staff plan meals that make it easier for students to choose a 

reimbursable meal and cashiers to confirm that a reimbursable meal has 

been selected. 

USDA Has Not Focused Its 

Own Oversight Efforts on 

Identifying or Addressing 

Meal Counting and 

Claiming Errors 

USDA’s oversight efforts have not directly focused on identifying or 

addressing meal counting and claiming errors. While FNS regional offices 

conduct a management evaluation of each state’s oversight of the school 

meal programs, these evaluations do not directly focus on identifying and 

addressing meal counting and claiming errors. Although USDA’s annual 

guidance on management evaluations indicates that regions should 

examine findings from some state administrative reviews of SFAs, it does 

not specify meal counting and claiming procedures as an area to focus on. 

Officials we spoke to in six of the seven FNS regional offices stated that 

management evaluations are generally ineffective at providing information 

on meal counting and claiming errors, in part because they are structured 

 

24Prior to fiscal year 2009, the number of states receiving these grants ranged from 3 to 8 in 

each year. 

25States are required to conduct a School Meals Initiative review of each SFA once during 

each 5-year review cycle. States can opt to conduct these reviews concurrently with those 

conducted under the coordinated review effort, but this is not required. 

26The National Food Service Management Institute was permanently authorized by 

Congress in 1994. The institute was established to carry out activities to improve the 

general operation and quality of the school meal programs. These activities include 

conducting research and providing training and technical assistance to states and food 

service personnel. 

Page 18 GAO-09-814 School Meal Programs
 

to focus more generally on state administration of the programs. Officials 

in some of the regional offices could not provide us with information on 

the extent of meal counting and claiming errors in the states they oversee. 

In addition, while regional offices submit management evaluation reports 

to USDA headquarters when they are completed, headquarters officials 

said that they do not currently analyze these reports to develop nationalor regional-level themes and trends.27 Finally, USDA has not updated its 

manual on meal counting and claiming procedures since it was originally 

published in 1991, though some states reported through our survey that an 

updated federal meal counting and claiming manual would assist their 

efforts. A USDA official reported that the manual was published during 

initial implementation of the coordinated review effort. While USDA 

recently updated the forms and instructions related to that effort, this 

manual has not been updated, nor was it available on USDA’s Web site at 

the time of our review. 

In contrast, USDA’s efforts have focused on addressing school meal 

program errors related to the certification of children as eligible for free 

and reduced price meals. Specifically, federal guidance for FNS regional 

offices’ management evaluations directs the regions to review state efforts 

to improve the accuracy of information used for certification. In January 

2008, USDA also issued an updated manual on certification.28 In addition, 

USDA worked with Congress to ensure that the Child Nutrition and WIC 

Reauthorization Act of 2004 included multiple changes to school meal 

programs to help address certification problems.29 For example, the act 

simplified the certification process by requiring a single application for all 

eligible children in the household and eligibility determinations to be in 

effect for the entire school year. 

One FNS regional official suggested that the approach USDA took to 

address certification errors nationally may be a model to address meal 

counting and claiming errors. USDA headquarters’ officials acknowledged 

that, in the past, the agency considered certification to be the primary 

source of improper payments in the school meal programs, and a few 

officials in headquarters and the regions said that they were surprised by 

 

27However, USDA headquarters officials stated that they are currently considering ways to 

more effectively use the data contained in these reports. 

28USDA, FNS, Child Nutrition Programs, “Eligibility Manual for School Meals: Federal 

Policy for Determining and Verifying Eligibility,” January 2008. 

29USDA has since offered grants to states to assist with implementation of these changes. 

Page 19 GAO-09-814 School Meal Programs
 

the APEC findings on the extent of meal counting and claiming errors. 

However, headquarters officials also said that the agency has recognized 

for many years that both erroneous meal counting and claiming and 

certification procedures cause improper payments. Before the APEC study 

findings on improper payments in the school meal programs were 

released, USDA’s Inspector General issued multiple reports on 

administration of these programs in selected school districts that found 

problems with meal counting and claiming procedures. For example, many 

of the reports issued from 2002 to 2007 found problems with SFA annual 

on-site reviews and edit checks performed on meal claims. Many of these 

reports also found that meal counting and claiming errors resulted in 

overpayments of federal funds. (For more information on the reports 

reviewed, see app. I.) 

USDA also collects annual data on findings from state administrative 

reviews of SFAs, but it does not use these data to assess meal counting 

and claiming errors.30 The “Standards for Internal Control in the Federal 

Government” states that agencies should monitor performance measures 

and indicators, which may be accomplished by assessing data, to 

determine appropriate actions to be taken. However, a USDA official said 

that the state review data are not used systematically for oversight 

purposes and are instead used periodically to provide information for 

agency publications and answer questions related to state reviews. While, 

in the past, USDA analyzed these data for trends and error-prone areas, 

officials said they have not done so for several years, in part due to 

resource constraints. These data include several pieces of information 

about meal counting and claiming errors in SFAs reviewed by states, such 

as the number of lunches observed that were erroneously counted as 

reimbursable because they did not meet federal menu planning and 

nutrition requirements and the value of over-claims resulting from meal 

counting and claiming errors. As a result, these data provide general 

information on the frequency with which meal counting and claiming 

errors are occurring in states. However, because states are not required to 

identify the SFAs reviewed in each year, and states are only required to 

review each SFA once during each 5-year review cycle, these data are also 

limited in their ability to provide information on specific SFAs with errors. 

Further, because states are not required to conduct administrative reviews 

 

30At the end of every year, each state submits an FNS-640 report to FNS, which summarizes 

findings from all of the SFA reviews the state conducted during that year. 

Page 20 GAO-09-814 School Meal Programs
 

of the School Breakfast Program, these data lack information about 

breakfast program errors. 

In the current economic environment, as increased numbers of families 

struggle to stay financially afloat and more children qualify for free or 

reduced-price meals, it is of even greater importance that federal dollars 

be effectively spent to meet the school meal programs’ goal of providing 

nutritious meals to children in schools. The APEC study’s estimate of $860 

million in improper payments resulting from meal counting and claiming 

errors provided new information about weaknesses in the school meal 

programs and successfully pinpointed areas, such as the breakfast 

program, that are particularly vulnerable. However, this information has 

not yet been fully utilized to modify program oversight at the federal, state, 

and local levels in order to improve efforts to identify and address errors. 

Conclusions 

Although the federally required oversight and monitoring processes for the 

school meal programs are designed to, in part, identify and address meal 

counting and claiming errors, gaps in these processes limit their strength 

as an internal control. The absence of a requirement to include the 

breakfast program in state and SFA reviews, as well as ineffective SFA 

annual reviews of schools, impede program monitoring efforts and leave 

the government vulnerable to continued erroneous payments. Further, 

outdated federal manuals and guidance may hinder SFA efforts to design 

or implement effective counting and claiming procedures, which also 

leaves the government vulnerable to continued erroneous payments. At 

the federal level, while the lack of data on both specific SFAs reviewed 

each year and errors in the breakfast program hinder USDA’s oversight 

ability, the agency is also missing an opportunity to use the data they 

already collect to identify states with significant counting and claiming 

errors and target assistance to areas of greatest risk. 

Finally, until officials who administer the school meal programs focus 

their attention on meal counting and claiming errors, it is unlikely that 

needed improvements will occur. While meal counting and claiming errors 

are often the result of basic human errors, such as the inaccurate addition 

of meal counts or incorrectly counting a meal as reimbursable because 

children are moving too quickly through the lunch line, holding states and 

SFAs accountable for implementing corrective actions can help minimize 

error frequency. 

Page 21 GAO-09-814 School Meal Programs
 

To help states and SFAs improve their ability to identify and address meal 

counting and claiming errors, we recommend that the Secretary of 

Agriculture take the following actions: 

• Require states to include the School Breakfast Program in their state 

administrative reviews of SFAs and require SFAs to include this program 

in their annual on-site reviews. 

• Update the 1991 USDA manual on meal counting and claiming procedures 

to ensure that current guidance is reflected. 

• Develop additional guidance and technical assistance for federallyrequired SFA annual on-site reviews. For example, USDA, through its Web 

site, could provide a model form to be used for on-site reviews that 

indicates the aspects of meal counting and claiming procedures to review, 

or the Department could work through the National Food Service 

Management Institute or another organization to provide SFAs with 

technical assistance aimed at improving the quality of on-site reviews. 

• Explore the feasibility of requiring SFAs to conduct third-party annual onsite reviews to ensure independence. 

In addition, to assist federal efforts to target resources to states and SFAs 

at the greatest risk for these errors, we recommend that the Secretary of 

Agriculture: 

• Develop procedures for using state administrative review data reported to 

FNS to assess risks and target oversight efforts associated with meal 

counting and claiming errors, and modify the FNS form on which states 

report the data so that it includes identification of which SFAs were 

reviewed each year and information from School Breakfast Program 

reviews. 

We provided a draft of this report to USDA for review and comment. In 

oral comments, USDA officials concurred with our recommendations. 

Officials also provided technical comments, which we incorporated into 

the report as appropriate. 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 22 GAO-09-814 School Meal Programs
 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to relevant 

congressional committees, the Secretary of Agriculture, and other 

interested parties. The report also will be available at no charge on the 

GAO Web site at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact me 

at (202) 512-7215 or brownke@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix II. 

Sincerely yours, 

Kay E. Brown 

Director, Education, Workforce, 

 and Income Security Issues 

Page 23 GAO-09-814 School Meal Programs
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 24 GAO-09-814 

Appendix I: Objectives, Scope, and 

Methodology 

To obtain information on federal, state, and local efforts to identify and 

reduce meal counting and claiming errors in the school meal programs, we 

used several methods. We reviewed pertinent federal laws and regulations, 

agency guidance, studies, and data, as well as interviewed U.S. 

Department of Agriculture (USDA), Food and Nutrition Service (FNS) 

officials in headquarters and all seven regional offices. We also conducted 

a Web survey of all states and site visits to six states and Washington, D.C. 

To obtain additional background information, we interviewed staff at the 

School Nutrition Association and the National Food Service Management 

Institute, and to obtain additional information on automated point of sale 

systems, we interviewed staff from two vendors of these systems—

MealTime/CLM Group and School-Link Technologies. 

We conducted this performance audit from August 2008 to September 

2009, in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Federal Studies and Data To provide context for our analysis of actions taken to identify and 

address meal counting and claiming errors, we reviewed information on 

these errors from FNS’s “Access, Participation, Eligibility, and 

Certification Study,” which was published in 2007.1

 This study provided 

the first national picture of improper payments in the National School 

Lunch Program and School Breakfast Program related to cashier/meal 

counting errors and aggregation/meal claiming errors. We determined th

these data are sufficiently reliable for the purposes of our rev

at 

iew. 

 

Reviews of the school meal programs conducted by the USDA Inspector 

General’s office also provided context on meal counting and claiming 

errors. As a result, we reviewed Inspector General reports issued from 

2002 to 2007 that addressed administration of the school meal programs in 

selected school districts nationwide. Because of our interest in meal 

counting and claiming errors generally, we did not review Inspector 

1

USDA, FNS, Office of Research, Nutrition and Analysis, “NSLP/SBP Access, Participation, 

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

Study Findings,” by Michael Ponza, et al. Project Officer: John R. Endahl (Alexandria, Va.: 

2007). 

 School Meal Programs 
Appendix I: Objectives, Scope, and 

Methodology 

General reports that specifically examined food service management 

companies’ involvement in administration of the school meal programs. 

We reviewed reports addressing school districts in the following cities: 

Milwaukee, Wisconsin; Liberal, Kansas; Chicago, Illinois; Philadelphia, 

Pennsylvania; Kearney, Missouri; Platte City, Missouri; Leavenworth, 

Kansas; Bellwood, Illinois; Girard, Kansas; Effingham, Kansas; and New 

York City, New York. We also interviewed an official from the Inspector 

General’s office to gather background information on the objectives, 

scope, and methodology for these reviews. 

To gather additional information on meal counting and claiming errors 

nationwide, we reviewed USDA FNS headquarters’ data on state 

administrative review findings for school years 1998-1999 through 2002-

2003. States report these data annually to FNS on the FNS-640 form, and 

FNS compiles datasets corresponding with the 5-year review cycles. We 

reviewed data from the most recently completed 5-year cycle for which 

full data was available at the time of our analysis and interviewed FNS 

officials to gather additional information about the data. Although these 

data have limitations, including that states do not always review all school 

food authorities (SFA) providing the school meal programs nationwide 

within each 5-year cycle, we determined that they are sufficiently reliable 

for the limited purposes of our review. 

Survey of States To obtain national information on state efforts to identify and address 

counting and claiming errors in the school meal programs, we conducted a 

Web survey of state child nutrition program directors in all 50 states and 

the District of Columbia between February and March 2009. All of the 

state child nutrition program directors responded to the survey.2

 The 

survey included questions about the extent to which states have identified 

meal counting and claiming errors within their SFAs, state and SFA 

processes to identify and reduce errors, related state assistance provided 

to SFAs, challenges states and SFAs have experienced in identifying and 

reducing errors, and support provided by FNS to help states and SFAs 

address errors. 

 

2

In two states, the school meal programs are overseen by two different state entities, 

therefore, we surveyed both officials in those states, for a total of 53 child nutrition 

program directors. We chose not to survey child nutrition program directors from Guam, 

Puerto Rico, or the U.S. Virgin Islands. 

Page 25 GAO-09-814 School Meal Programs
Appendix I: Objectives, Scope, and 

Methodology 

The practical difficulties of conducting any survey may introduce errors, 

such as variations in how respondents interpret questions and their 

willingness to offer accurate responses. We took several steps to minimize 

these errors, including pretesting draft instruments and using a Web-based 

administration system. Specifically, we pretested draft instruments with 

state child nutrition program directors from four states (Maryland, 

Mississippi, New Mexico, and New York) in January 2009. We selected 

pretest states based on geographical disparity and the large percentage of 

students eligible for free and reduced price school meals in those states. 

We also considered recommendations from FNS regional offices. In the 

pretests we inquired about clarity, precision, and objectivity of the 

questions, in addition to flow and layout of the survey. We revised the final 

survey based on pretest results. Another step we took to minimize errors 

was using a Web-based survey. By allowing respondents to enter their 

responses directly into an electronic instrument, this method 

automatically created a record for each respondent in a data file and 

eliminated the need for and the errors associated with a manual data entry 

process. To further minimize errors, programs used to analyze the survey 

data and make estimations were independently verified to ensure 

accuracy. 

While we did not validate specific information that states reported through 

our survey, we took several steps to ensure that the information was 

sufficiently reliable for the purposes of this report. For example, during 

pre-testing, we took steps to ensure definitions and terms used in the 

survey were clear and familiar to the respondents, categories provided in 

closed-ended questions were complete and exclusive, and the ordering of 

survey sections and the questions within each section were appropriate. 

Further, after states completed the survey, we reviewed the responses, 

identified those that required further clarification, and conducted followup interviews with respondents to ensure the information they provided 

was reasonable. In our review of the data, we also identified and logically 

fixed skip pattern errors—questions that respondents should have skipped 

but did not. On the basis of these checks, we believe our survey data are 

sufficiently reliable for the purposes of our work. 

Page 26 GAO-09-814 School Meal Programs
Appendix I: Objectives, Scope, and 

Methodology 

To gather additional information on state and local efforts to identify and 

address counting and claiming errors in the school meal programs, we 

conducted site visits to states in six of the seven FNS regions from 

September 2008 to March 2009.3

 We visited one state (California, Illinois, 

Massachusetts, Mississippi, and Texas) in each of the regions, except in 

the Mid Atlantic Region, where we visited both Washington, D.C., and 

Maryland. States selected provided geographic variation and had both high 

levels of school meal errors found during state administrative reviews and 

relatively high percentages of students eligible for free and reduced-price 

meals. We also considered recommendations of the relevant FNS regional 

offices when selecting states to visit. In addition, during site selection, we 

interviewed child nutrition program officials from Florida, Indiana, and 

New York to better understand state issues related to meal counting and 

claiming. 

Site Visits 

During each site visit, we interviewed state-level child nutrition program 

directors, as well as officials from two to three SFAs that either had 

experienced significant meal counting and claiming errors or had systems 

in place that were considered effective at identifying and reducing such 

errors. The 15 SFAs selected also provided some variation in school 

district type, including public, private, and charter. Through interviews 

with state and SFA officials, we collected information on actions taken 

and policies in place to identify and address meal counting and claiming 

errors and the types of challenges states and SFAs face in their efforts to 

do so. For each SFA, we also reviewed recent state review findings on 

meal counting and claiming errors and observed school meal procedures 

in one or more schools.4

 We cannot generalize our findings beyond the 

states and SFAs we visited. 

 

3

We chose not to visit a state in the Mountain Plains Region because of the relatively low 

percentage of students participating in the school meal programs in those states. 

4

However, we were unable to observe school meal procedures in one SFA because the 

schools were closed due to inclement weather on the day of our visit. 

Page 27 GAO-09-814 School Meal Programs
Appendix II: 

A

GAO Contact and Staff 

cknowledgments 

Page 28 GAO-09-814 

Appendix II: GAO Contact and Staff 

Acknowledgments 

Kay Brown (202) 512-7215 or brownke@gao.gov

Blake Ainsworth and Jeremy Cox, Assistant Directors; Rachel Frisk and 

Anjali Tekchandani, Analysts-in-Charge; Kris Trueblood; Joanie Lofgren; 

Walter Vance; Joanna Chan; Jim Rebbe; Kate van Gelder; and Mimi Nguyen 

also made significant contributions to this report. 

 School Meal Programs 

GAO Contact 

Staff 

Acknowledgments 

(130871) 
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Ralph Dawn, Managing Director, dawnr@gao.gov, (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, DC 20548 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

Public Affairs 

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