School Nutrition: USDA Has Efforts Underway to Help Address Ongoing Challenges Implementing Changes in Nutrition Standards
Published: 2015-09-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Healthy, Hunger-Free Kids Act of 2010 required USDA to update nutrition standards for school lunches and breakfasts and add standards for other food sold in schools, known as competitive foods. In response, USDA set new nutrition requirements, including limits on calories, sodium, and fats. Previously, GAO reported on the implementation of changes to school lunches in school year 2012-2013. Since then, additional requirements for lunches have taken effect, as well as new requirements for breakfasts and competitive foods. GAO was asked to review implementation of the nutrition changes to school food.
GAO reviewed (1) recent trends in school meals participation, (2) challenges SFAs faced in implementing the new requirements for school meals, (3) challenges SFAs and districts faced in implementing new requirements for competitive foods, and (4) USDA assistance in implementing the changes.
GAO reviewed relevant federal laws, regulations, and guidance; analyzed federal school meals participation data from school years 2000-2001 through 2013-2014; reviewed implementation in the same eight school districts visited for the report on school year 2012-2013 lunch changes, selected to provide variation in geographic location and certain district and food service characteristics; and interviewed USDA and state officials, as well as food industry and stakeholder groups.
section_title: What GAO Found
paragraphs: Nationwide, participation in the National School Lunch Program declined by 1.4 million children (or 4.5 percent) from school year 2010-2011 through school year 2013-2014, to 30.4 million children. The participation rate of enrolled students also declined, from 62 to 58 percent. Seven of eight states that GAO interviewed reported that challenges with student acceptance of changes made to comply with new federal nutrition requirements contributed to the decrease. Also, four of eight states noted that recent required increases in the price of lunch may have decreased participation among some students. At the same time, nationwide participation in the breakfast program continued its trend of steady increases, which can be explained, in part, by program expansion into more schools.
The U.S. Department of Agriculture (USDA), states, and the eight School Food Authorities (SFAs) GAO reviewed, which administer meal programs in school districts, reported some ongoing challenges with meal requirements; however some SFAs noted success in certain areas. For example, five of eight SFAs, described continuing challenges with plate waste, that is, students taking required foods and then not eating them. However, officials in the other three, as well as GAO's mealtime observations across the two school years, suggest that plate waste may be decreasing in some SFAs. Also, five of the SFAs reported difficulty serving certain required food items in ways that appeal to students, though others reported some success. Regarding sodium, SFA, state, and food company officials expressed concerns about meeting future targets, which USDA plans to phase in over the next 8 years. To address these concerns, USDA is gathering information from SFAs and the food industry on progress toward reducing sodium levels in school meals.
New requirements for competitive foods—foods sold to students in schools other than through the school meals programs—also challenged SFAs and schools during school year 2014-2015. Six of eight SFAs reported difficulty procuring items that met the new requirements, particularly at the beginning of the school year. Also, four SFAs and two school groups selling competitive foods in the eight districts GAO reviewed reported decreased revenues due to lower student demand for products that comply with the requirements. In addition, SFA and state officials reported issues with ensuring compliance and providing oversight of these sales. To identify and help address such issues, USDA recently required states to begin including competitive foods in their periodic reviews of SFAs.
Officials from five states and four SFAs reported that USDA's assistance in implementing these changes has been helpful or improving over time; however, some SFAs noted problems with the amount or clarity of the guidance. USDA has initiated efforts to assist SFAs, such as by conducting webinars on a variety of topics, including menu planning. At the same time, officials from three of eight SFAs said USDA guidance on the new requirements—comprising nearly 4,700 pages issued from January 2012 through April 2015—has been challenging to keep up with. However, according to USDA, the substantial changes to nutrition standards have already occurred, and therefore, the need for additional guidance should decrease in future years. Moreover, USDA has provided other types of assistance that help clarify the guidance, including initiatives that facilitate the sharing of best practices and provide peer mentoring.
section_title: What GAO Recommends
paragraphs: GAO is not making any recommendations.

section_title: Letter
paragraphs: In fiscal year 2014, the National School Lunch Program and the School  Breakfast Program, which are intended to promote the health and well- being of schoolchildren, provided school meals to an estimated 30.4  million and 13.6 million children, respectively, supported in part through  federal subsidies and commodities totaling $16.3 billion. The U.S.  Department of Agriculture (USDA) administers the school meals  programs at the federal level and, under agreements with state agencies,  local school food authorities (SFA)—which are generally aligned with  school districts—serve meals to children in schools. Federal standards for  the content of school lunches and breakfasts have existed since the  programs were created; however, the Healthy, Hunger-Free Kids Act of  2010, which most recently reauthorized school meal programs, required  that these standards be updated. More specifically, the Act required  USDA to update the standards for the content of school meals based on  recommendations from the Institute of Medicine. The Act also required  USDA to establish nutrition standards for all other foods and beverages  sold in schools, commonly known as competitive foods. The changes to  lunch, breakfast, and competitive foods were required in order to improve  children’s diets and help reduce childhood obesity. USDA has established  these new requirements over the last few years.
In the 2012-2013 school year, as many of the new nutrition standards for  lunches were implemented, both USDA and the media reported that  states, SFAs, school officials, parents, and students raised issues about  the lunch changes. In June 2013 and January 2014, we reported to  Congress on challenges SFAs encountered in implementing the lunch  changes and recommended that USDA make modifications to some of  the new lunch requirements and take steps to improve program  oversight. Subsequently, additional nutrition requirements for lunches  have taken effect, as well as new nutrition requirements for breakfasts  and competitive foods. Accordingly, you asked us to review the current  status of local implementation of the school meals and competitive food  nutrition requirements.
This report assesses: (1) recent trends in school meals participation; (2)  challenges that SFAs reported they continued to face in implementing the  new requirements for school lunch and school breakfast; (3) challenges  SFAs and schools reported they have faced during their first year  implementing the new requirements for competitive foods; and (4)  USDA’s efforts to assist with implementation of the new requirements for  school lunch, school breakfast, and competitive foods.
For this study, we gathered information through several methods. First,  we reviewed relevant federal laws, regulations, and guidance; analyzed  national school meals participation data from school years 2000-2001  through 2013-2014; and interviewed USDA officials. Second, we  reviewed implementation in eight school districts across the country and  talked with their state agency officials who have knowledge of the  experiences of multiple school districts across their states. In addition, we  met with industry and stakeholder groups that vary in their perspectives  on the nutrition standards and implementation of the changes. More  specifically, to assess national school meals participation, we analyzed  USDA’s national data on meals served in the National School Lunch  Program and the School Breakfast Program and reviewed the  department’s method for determining school meals participation from  these data. To assess the reliability of the data, we interviewed USDA  officials, reviewed related documentation, and compared the data we  received from USDA with its published data. We determined that these  data and the participation methodology are sufficiently reliable for the  purposes of this report. To gather information on challenges directly from  those affected by the changes to food in schools, we contacted the eight  school districts in eight states across the country that we had visited as  part of our prior study of implementation of the new school lunch  requirements in school year 2012-2013. From December 2014 through  March 2015, we visited seven of the districts and gathered information  from the eighth district through phone interviews. The school districts  selected for these visits provide variation across geographic location,  district size, and certain characteristics of the student population and  district food services. In each district we visited, we met with SFA staff at  the district and school levels, school administrators, and students, and we  also observed lunch and breakfast, as well as competitive food sales, in  at least two schools of different grade levels, for a total of 14 schools.  Contacting these districts and states a second time provides a short-term  longitudinal perspective on challenges related to implementation of the  phased-in changes. We cannot generalize our findings from the site visits  beyond the school districts we visited or the findings from states beyond  the eight states we interviewed. To understand the scale and scope of  assistance USDA has provided, we interviewed USDA officials, reviewed  relevant agency documents, talked with states and SFAs about their  perspectives on the assistance provided, and analyzed guidance memos  USDA issued on the nutrition changes from October 2013 through May  2015. We chose this time period in order to continue our previous  analysis of this guidance, as in our prior report on the school lunch  nutrition changes, we analyzed guidance issued from January 2011  through September 2013.
For additional information on the report’s scope and methodology, see  appendix I.
We conducted this work from November 2014 through August 2015 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The two largest federal school meals programs, the National School  Lunch Program, established in 1946, and the School Breakfast Program,  permanently established in 1975, aim to address problems of hunger,  food insecurity, and poor nutrition by providing nutritious meals to children  in schools. Although federal requirements for the content of school meals  have existed since the programs began, as research has documented the  increasing incidence of children who are overweight and obese in the  United States, the federal government has taken steps to improve the  nutritional content of meals. The Healthy, Hunger-Free Kids Act of 2010  required USDA to update federal requirements for school lunches,  breakfasts, and to establish standards for competitive foods—foods sold  to children in schools other than through the school meals programs.  USDA issued final regulations that made changes to many of the meal  content and nutrition requirements in January 2012, and many of the new  lunch requirements were required to be implemented beginning in school  year 2012-2013, with changes to breakfast generally beginning in school  year 2013-2014. USDA issued interim final regulations that established  new nutrition standards for competitive foods in June 2013, and USDA  required them to be implemented beginning in school year 2014-2015.
For lunches, USDA regulations implementing the Healthy, Hunger-Free  Kids Act of 2010 made changes to meal components and nutrition  standards. Regarding meal components—fruits, vegetables, meats,  grains, and milk—lunches must now include fat-free or low-fat milk and  both fruit and vegetable choices. While students may be allowed to  decline two of the five lunch components they are offered, they must  select at least one half cup of fruits or vegetables as part of their meal in  order for it to be reimbursable. (See fig. 1.) For nutrition standards, the  regulations include minimum and maximum calorie levels for lunches and  require that lunches do not include trans fat and contain reduced amounts  of sodium and saturated fat.
USDA regulations also phased in some of the new lunch requirements.  For example, in school year 2012-2013, USDA initially required that at  least 50 percent of grain products offered in lunches had to be whole  grain-rich—containing at least 50 percent whole grains—during the  school week. In school year 2014-2015, the whole grain-rich requirement  was increased to 100 percent of grain products, although SFAs may  request temporary exemptions from this requirement from their states.  USDA regulations also phase in requirements for sodium reductions in  lunches. The Target 1 sodium limits became effective in school year  2014-2015, and future sodium reductions are set for school years 2017- 2018 (Target 2) and 2022-2023 (Target 3). (See table 1.) However, USDA  cannot implement these future reductions until the latest scientific  research establishes that they are beneficial to children.
For breakfast, USDA’s regulations establish three meal components— fruit, grains, and milk—and require that breakfasts include whole grain- rich foods and only fat-free or low-fat milk. (See fig. 2.) Starting in school  year 2014-2015, schools must offer one cup of fruit with each breakfast  each day and may offer vegetables in place of fruit. If a school chooses  to offer four or more food items, a child must take at least three, including  at least one half cup of fruit or vegetable substitute, in order to have a  reimbursable meal. In addition, the new nutrition standards include  minimum and maximum calorie levels for breakfasts and require that  breakfasts include no trans fat and reduced amounts of sodium and  saturated fat. Similar to lunch, the whole grain-rich requirement was  phased in, with exemptions available, and the first sodium target was  effective in school year 2014-2015, with further reductions in future years.  (See table 2.)
For competitive foods, USDA regulations establish nutrition standards for  foods or beverages, other than school meals, sold to children in schools  during the school day, by the SFA or school groups. Competitive food  sales may take place at fundraisers on the school campus, as well as at  specific venues in schools, such as vending machines, school stores, and  a la carte lines in the cafeteria, through which the SFA sells individually  priced food and beverage items. The new federal competitive food  requirements include limits on calories, sugars, total and saturated fat,  trans fat, and sodium, establish new standards for beverages, and add  whole grain-rich requirements. Competitive foods sold in schools  generally must meet these requirements during the school day, which the  regulations define as beginning at midnight and ending 30 minutes after  the end of the school day. However, USDA has provided flexibility to  states to grant exemptions from the competitive food requirements for  infrequent fundraisers held during the school day, allowing states to set  the number of fundraisers schools can hold in which the food items being  sold do not have to meet competitive food requirements. Outside of the  school day, food sales also do not have to comply with the requirements.  Before the Healthy, Hunger-Free Kids Act of 2010, competitive foods  were largely unregulated at the federal level, with only minimal restrictions  prohibiting the sale of certain competitive foods, known as foods of  minimal nutrition value, during meal periods in school cafeterias and other  food service areas.
section_title: National School Lunch Participation Continued to Decline in School Year 2013- 2014, While Breakfast Participation Continued to Increase
subsections: section_title: School Lunch Participation Continued to Decline in School Year 2013-2014
paragraphs: Nationwide, participation in the National School Lunch Program has  declined in recent years after having increased steadily for more than a  decade. In our January 2014 report, we found that total student  participation in the National School Lunch Program—the total number of  students who ate school lunches—dropped by a cumulative 1.2 million  students (or 3.7 percent) from school years 2010-2011 through 2012- 2013, with most of the decrease occurring during school year 2012- 2013. According to our recent analysis of USDA data, school lunch  participation continued to decline during school year 2013-2014, reaching  a cumulative decline of 1.4 million students (or 4.5 percent) since school  year 2010-2011. (See fig. 3.) The participation rate, which measures the  proportion of all students in schools that take part in the National School  Lunch Program who ate school lunches, also declined during this period,  falling from 62 percent in school year 2010-2011 to 58 percent in school  year 2013-2014.
The decrease in the total number of students eating school lunches  during the last three school years was driven primarily by a decrease in  students paying full price for meals. Based on family income, children  who participate in school meals programs either pay full price or qualify to  receive free or reduced-price meals. The number of students paying full  price for meals declined by two million, a decrease that could be caused  by students choosing to no longer purchase lunch at school or by  students becoming eligible for free or reduced-price meals. The decline  in students paying full price for lunch exceeded the increase in the  number of students eating free lunches during the same time period. (See  fig. 4.)
State and SFA officials told us that several factors likely influenced  decreases in participation in the school lunch program, though the extent  to which each factor affected participation is unclear. For example,  officials from all the SFAs we interviewed during school year 2012-2013  reported that student acceptance of the lunch content changes was a  challenge, which we heard again from officials we interviewed during  school year 2014-2015. Further, officials from seven of the eight states  we interviewed in school year 2014-2015 reported that the decreases in  lunch participation were influenced by student acceptance of the changes  made to comply with the new lunch content and nutrition standards.  According to officials from four states, another factor that may have led to  lower participation among students paying full price for lunch is the  federally-required increase in the prices of paid lunches in certain  districts—also known as paid lunch equity. These federally-required  price increases may have resulted in students who previously purchased  school lunches deciding not to purchase lunch at the higher price.
The increase in lunch participation by students who qualify for free  lunches may be influenced by several factors. USDA has reported that  the introduction of the Community Eligibility Provision, which allows  qualifying, high-poverty schools to provide free meals to all students, is  intended to remove the stigma of receiving free meals and reduce  administrative barriers to student participation. Other factors that may  have influenced the increase in participation by students who receive free  school lunch include the economic downturn that began in 2007 and  adjustments made to how student eligibility for free and reduced-price  meals is determined.
As we previously found in our January 2014 report, the impact of other  factors at the local level on lunch participation may vary. Specifically,  changes to district and school policies that affect school lunch may  increase or decrease lunch participation. For example, in 2014, officials in  three of the eight districts we visited noted that the time allotted for lunch  periods may affect participation. In addition, USDA officials told us that  school closures, mergers, moves, consolidation due to economic  conditions, and issues with food service management companies may  affect school lunch participation.
section_title: School Breakfast Participation Continued to Increase in School Year 2013-2014
paragraphs: Participation in the School Breakfast Program continued its upward trend  during school year 2013-2014, continuing more than a decade of steady  increases. According to our analysis of USDA data, participation in the  School Breakfast Program grew by 1.4 million students (or 12 percent)  from school year 2010-2011 through school year 2013-2014, to a total of  13.5 million students. (See fig. 5.) The participation rate also increased  during this period, growing from 26 percent in school year 2010-2011 to  28 percent in school year 2013-2014. In comparison with school lunch,  the number of students participating in school breakfast was less than  half of the number participating in school lunch in school year 2013-2014.
According to USDA data, the increases in School Breakfast Program  participation can be explained, in part, by program expansion.
Specifically, since school year 2010-2011, the program has expanded to  more than 1,500 additional schools, while also increasing the proportion  of enrolled students eating breakfast. That growth has been driven largely  by increases in the number of students eating breakfasts that receive free  meals, which have accounted for 1.3 million of the 1.4 million additional  average daily breakfasts served from school years 2010-2011 through  2013-2014. (See fig. 6.) Breakfast has also benefitted from efforts  intended to increase participation using alternative formats, such as  providing students with breakfast in the classroom and breakfast after the  school day has started. USDA found in 2009 that the probability of  student participation in school breakfast increases when breakfast is  served in the classroom rather than in the cafeteria, and that the more  time students have to eat breakfast, the more student participation  increases.
section_title: SFAs Continue to Report Challenges with New School Meals Requirements and Expressed Concern about Future Sodium Restrictions
subsections: section_title: Some Challenges We Reported on Previously Have Persisted
paragraphs: SFAs and states reported that some of the challenges they have  experienced meeting the new school meals requirements have persisted  since school year 2012-2013, such as increased plate waste. Plate waste  occurs when students take food required for a school meal, but then  choose not to eat it. In our January 2014 report, 48 states reported that  plate waste—particularly for fruits and vegetables—was a challenge for  their SFAs in school year 2012-2013. Further, in 7 of the 17 schools we  visited in school year 2012-2013, we saw many students throw away  some or all of their fruits and vegetables at lunch. During school year  2014-2015, directors and staff from five of the eight SFAs we reviewed  indicated that this issue has persisted as a challenge, though staff from  three SFAs reported that plate waste was not a problem at their schools.  Our lunch observations suggest that plate waste may be beginning to  decrease as students adjust to school meals that meet the new  requirements. Specifically, the plate waste we observed when visiting  schools in school year 2014-2015 was generally limited to a small number  of students throwing away some of their fruits and vegetables in 7 of the  14 schools. SFA food preparation changes and student acceptance of  fruits and vegetables may be helping to reduce fruit and vegetable waste  in some districts. For example, officials from three SFAs noted that it is  sometimes difficult for students to eat whole fruit during a meal, and one  SFA has responded by giving pre-cut, rather than whole, fruit to  elementary and middle school students. In addition, when we asked  students what they like about school lunch, students we spoke with in 13  of the 14 schools generally reported liking fruit and vegetable options, and  those at 5 schools highlighted fruits or vegetables as their favorite  breakfast or lunch items.
Although there has been some progress, poor student acceptance of  certain foods is another longstanding challenge that SFAs continued to  report. For example, in our prior work, we found that SFAs were  challenged by student acceptance of some whole grain-rich products in  school year 2012-2013. With the requirement increasing from half of  grains served in meals having to meet the whole grain-rich definition  beginning in school year 2012-2013, to all grains in school year 2014- 2015, we found that these acceptance challenges have continued for  most SFAs we reviewed. Specifically, directors and staff from seven of  eight SFAs told us that students do not like certain whole grain-rich foods,  so getting them to take and eat them continues to be a challenge.  Representatives from five of these SFAs highlighted whole grain pasta as  being particularly challenging to serve, with one noting, for example, that  whole grain-rich pasta loses structural integrity soon after being served,  becoming unappealing to students. While none of the SFAs we visited  had applied for the temporary pasta exemption or grain product  exemption made available by USDA, we found that two had  nevertheless been serving pasta that was not in compliance with the  whole grain-rich requirement. For example, one SFA director told us that  she was not serving compliant lasagna noodles because she was unable  to find whole grain-rich noodles that would work well in the SFA’s recipe.  In addition, SFA directors and staff mentioned whole grain-rich bread and  crackers as examples of other items that have been challenging to get  some students to accept. In our June 2013 testimony, we also found poor  student acceptance of vegetables in the beans and peas (legumes) and  red/orange vegetable subgroups, and we found during our recent SFA  visits that this challenge has persisted for five of the eight SFAs. For  example, two SFA directors reported that they have tried to replace  regular potatoes with sweet potatoes in fries or tater tots, but students  have not embraced the change. Also, one SFA director noted that even  when staff prepare a small amount of legumes, they end up throwing  some of it away because children do not take it.
Despite their persistence, the challenges around student acceptance that  we previously reported may be improving over time as students adjust to  the lunch changes and SFAs find more acceptable products and recipes.  Specifically, directors and staff from four SFAs we visited reported some  success in addressing challenges in obtaining student acceptance of  whole grains, including three that used white whole wheat flour and one  that mixed whole grains—such as rice—in with other foods rather than  serving them on their own. Another SFA director indicated that the SFA’s  early adoption of whole grain-enriched foods helped ease the transition to  meeting the federal standards, and student acceptance has improved  over time. The opportunities for SFAs to receive temporary exemptions  from whole grain requirements—both specifically for pasta and generally  for any grain product—were designed to help ease these challenges in  some SFAs across the country. Further, food industry representatives we  spoke with reported that they are taking steps to help schools improve  preparation of these products, which may also help improve student  acceptance. For example, representatives of three companies, including  one that produces pasta, said that they are currently focused on  educating SFAs and schools on preparation techniques that maximize  palatability of whole grain-rich products. In addition, directors from two  SFAs noted that they have found ways to incorporate legumes and  red/orange vegetables into dishes that students will eat. For example, one  said the SFA was able to incorporate red/orange vegetables into popular  harvest cake, pumpkin bars, and a sweet potato and apple side dish on  the elementary school menus in the fall, and another successfully  included black and refried beans in tacos.
In our prior work, we also found that managing food costs was a  significant challenge in school year 2012-2013. During our current  review, we found that managing food costs has persisted as a challenge  for several of the SFAs we visited. Specifically, 47 states reported that  food costs were a challenge for their SFAs in school year 2012-2013, and  all eight directors of SFAs we visited reported that fruit and vegetable  expenditures increased substantially from school year 2011-2012 to  school year 2012-2013. During our recent visits to SFAs, we found that  four of the eight SFA directors continue to report increased food costs  due to the new requirements for school meals, which three attributed, in  part, to increased costs for fruits and vegetables. In addition, two SFAs  reported a net financial loss from school years 2012-2013 to 2013-2014— a trend they expected to continue for school year 2014-2015—which they  said reduced their SFAs’ fund balances. In addition to increasing food  costs, several SFA and state officials highlighted increasing employee  wages and benefits as another major driver of SFAs’ increasing costs.
section_title: SFAs and States Are Concerned about Meeting Future Sodium Targets Without Industry Help
paragraphs: The 2014-2015 school year marked the first school year for which SFAs  were required to comply with sodium reductions as part of a planned  phase-in for new sodium limits for breakfast and lunch, and while the  eight SFAs we reviewed reported meeting the first sodium targets,  officials reported difficulties in doing so. For example, to meet the first  sodium target, three SFAs altered popular items to comply with the  requirements, and three SFAs removed popular items altogether— including certain cereals, biscuits and gravy, and chili. Staff from another  SFA said they had replaced all added salt with pepper, which resulted in  a strong pepper flavor for many foods, and other SFA staff reported  switching to low-sodium gravy and removing pickles from the condiment  station. Some students we spoke with in 6 of 14 schools made comments  about the lack of flavor in school meals that suggested they noticed the  changes SFAs made to meet the first targets. Further, we found that  students in two of the SFAs had attempted ways to add sodium to their  school meals, including bringing salt and pepper shakers to lunch in the  cafeteria (see fig. 7) and asking school faculty and administrators to  obtain additional condiment packets for them from the cafeteria. The  dietitian in the latter SFA noted that under the current sodium restrictions,  the SFA no longer allows students to take unlimited quantities of  condiments.
SFA directors, state officials, and industry representatives we interviewed  expressed concerns about the future sodium targets for school meals.  Directors and staff from three SFAs indicated that they made changes to  food that are within their control in order to meet the first sodium  requirements, and those from two noted that they are doubtful it will be  feasible to meet the future targets without changes made by the food  industry. Similarly, officials from three of eight states noted that SFAs’  success with meeting future sodium targets depends on industry’s ability  to manufacture compliant foods that students will eat. Representatives  from four of the eight food companies we interviewed said they  anticipated problems with developing foods that would meet future  targets. Three of the representatives noted that sodium is a necessary  component of certain products, including breads, meat, and cheese, so  reducing sodium content further in those products will be difficult. For  example, one company representative said that reduced sodium could  shorten products’ shelf lives. Representatives from two of the companies  that are already reformulating their food products to meet the future  targets said they have encountered challenges with respect to palatability  when testing these reformulated foods.
In addition, we found that uncertainty about when and if future targets will  be implemented may be delaying some industry progress toward  developing compliant products. For example, a representative from one  company said that the company is waiting to see if USDA will maintain  the first target as the ultimate sodium limit, in part because changing  formulations is expensive and time-intensive. Consistent with this,  officials from two states said they believe some food manufacturers may  be taking a wait-and-see approach to the sodium targets due to  uncertainty about the implementation of future targets, which could  impact the availability of low-sodium food products in the future. In April  2015, USDA officials told us that, consistent with the statutory  requirements, they have been examining the science around the health  effects of sodium, and they do not expect to make any policy decisions on  future sodium targets until the Dietary Guidelines for Americans  recommendations are released later this year.
In 2010, the National Academies’ Institute of Medicine reported that  several broad barriers precluded rapid and large reductions in the sodium  content of school meals, noting that most schoolchildren prefer salty food,  and that this preference should be expected to persist as long as children  are exposed to salty foods at home or elsewhere. Pointing to studies  showing that acceptance of diets with lower sodium content is more  successful if carried out gradually, the Institute of Medicine recommended  that USDA gradually phase in the sodium reductions in school meals over  10 years. However, the Institute of Medicine said that following a  phased-in approach may not remove all related challenges to student  acceptance, and SFAs will not be able to accomplish these reductions on  their own. The report noted that the food industry’s partnership is  essential because the current sodium content of many commercially  prepared foods available for school meals is moderately high or high, and  the food industry is responsible for the diversity and quality of these  foods. It also acknowledged the correlation between palatable foods at  school and school meals participation and concluded that it is unlikely that  children will be easily motivated to continue to eat foods they find  unappealing. Further, the report also noted that any loss of revenue  based on decreased participation presents a threat to the financial  stability of SFAs’ programs.
Recognizing the challenges related to implementation of the sodium  targets, USDA officials told us they have taken steps intended to assist  SFAs as they modify foods in preparation for the future targets. For  example, officials told us they began planning an initiative in the summer  of 2014 called “What’s Shaking? Creative Ways to Boost Flavor with Less  Sodium” with the goal of developing and sharing strategies for reducing  sodium levels in school meals. Officials reported that they have 36  partners in this initiative, including organizations focused on improving  public health and other federal agencies such as the Department of  Health and Human Services’ Centers for Disease Control and Prevention,  who began meeting in April 2015. USDA officials reported that they have  also held roundtable discussions and are planning future listening  sessions among districts to discuss and receive feedback on specific  challenges SFAs are encountering as they try to plan menus with reduced  sodium. An additional effort that may assist SFAs struggling with the  sodium reductions in the future is USDA’s training and peer-to-peer  mentoring program called “Team Up For School Nutrition Success,” which  aims to leverage successes from some SFAs by sharing best practices  with others that are struggling with specific aspects of implementing the  new nutrition requirements. The department has also made a number of  resources on reducing sodium in school meals available for SFAs on the  department’s website, including recipes, fact sheets, presentations, and  webinars.
USDA is also beginning to gather information from food producers about  their progress toward developing school meals that meet the future  sodium targets. In June 2015, the department requested proposals for a  study examining the market availability of foods that meet both the current  and future targets, as well as successes and challenges experienced by  the food industry and SFAs as they take steps to reduce sodium in school  meals. Among other things, the study aims to identify barriers the food  industry faces and expects to face in the future in providing schools with  lower sodium foods, as well as gauge progress made toward future  sodium targets. In addition, officials reported that they have conducted  some outreach to food industry representatives on the future sodium  targets, for example, by visiting a spice manufacturing company to  discuss alternative food preparation techniques that require little or no  added salt. USDA officials also said that they are gathering feedback on  trends related to new technologies and tactics industry is employing to  lower sodium levels in food. In July 2015, USDA officials noted that food  industry representatives they have talked to have committed to working  toward the future targets, but have also emphasized that research and  development efforts take time, and they do not want to compromise  quality or taste in producing compliant foods. USDA officials noted that  while they believe the sodium reductions in school meals can be  achieved, doing so will take time and energy and will require both industry  innovation and cooperation among SFAs, the food industry, USDA, and  other partners that promote good child nutrition.
section_title: SFAs and Schools Made Changes to Comply with the New Federal Competitive Food Standards and Faced Challenges with Procurement, Revenue, and Oversight
subsections: section_title: SFAs and School Groups Had to Make Product Changes and Had Procurement Challenges
paragraphs: While many states and school districts had pre-existing policies on  nutrition standards for competitive food sales when the new federal  requirements were established, SFAs and school groups in seven of the  eight districts we reviewed reported that they had to make changes to the  competitive foods they offered for sale in school year 2014-2015 to  comply. USDA reported that, by 2012, at least half of states had  competitive food standards for foods sold in schools through a la carte  sales in the cafeteria, vending machines, school stores, and snack bars,  and almost half had nutrition standards for foods sold through bake sales.  Six of the eight school districts we reviewed were in states that had pre- existing competitive food policies. However, pre-existing policies did not  eliminate the need for most SFAs to make changes to comply in school  year 2014-2015, as officials from seven of the eight SFAs we reviewed  said that they discontinued some products and added other products to  comply with the new federal standards. For example, some products,  such as candy, were discontinued entirely. Further, two of eight SFA  directors said that they stopped selling some items a la carte that were  served as part of the school lunch, such as a side salad with dressing,  peach cobbler, and fried potatoes, because the individual items did not  meet the competitive food requirements. At one school, because some  meal components met the competitive food requirements and others did  not, the SFA discontinued all meal component a la carte sales to avoid  confusing students. SFA directors, athletic directors, and a school store  manager said that non-SFA groups also had to change the products they  sold, for example, discontinuing sales of candy, donuts, chicken  sandwiches from a restaurant, and full calorie soda.
SFAs and school groups also added various compliant food products to  their competitive food sales. For example, some added products that had  been reformulated to comply with the new requirements, such as flavored  chips, puffed grain snacks, ice cream, and marshmallow cereal treats.  Sports drinks continued to be offered at some schools, but in their lower  calorie or no calorie versions and in small size bottles. Carbonated drinks,  which were generally previously prohibited by federal regulations from  being sold in school food service areas at mealtimes, were also added in  their low-calorie and no calorie forms to competitive food sales in high  school cafeterias at three of the eight SFAs we contacted.
Six of eight SFAs told us they had difficulty, particularly during the  beginning of school year 2014-2015, finding compliant competitive food  products and obtaining sufficient quantities of the products to meet  student demand. For example, two SFAs said they had a difficult time  obtaining products like compliant chips and marshmallow cereal treats.
Food industry representatives we spoke with reported that these  shortages were the result of initial difficulty estimating demand for the  new reformulated products. However, SFAs reported that these supply  challenges diminished as the year progressed.
section_title: Some SFAs and Schools Reported Reduced Revenues from Competitive Food Sales
paragraphs: SFAs reported concerns about revenue losses from switching to sales of  competitive foods that comply with the new federal nutrition requirements.  Of the five SFAs that provided us with information on their competitive  food sales from the beginning of school year 2014-2015 up to the time of  our visits, four told us that their competitive food sales had decreased in  comparison to the previous school year, while one SFA reported  increased competitive food sales. Specifically, reasons the SFAs gave for  reduced revenues included lost sales from some of the popular,  discontinued foods, and students not buying as much of the new foods  offered for sale. SFAs also reported that the cost of compliant items was  greater than the cost of noncompliant items sold previously, but they did  not feel that they could increase prices to the same degree, which  resulted in lower profits. The SFA director that reported increased sales  said that her a la carte sales were slightly higher part way through the  2014-2015 school year, possibly because she had not raised prices and  that she offered a wide variety of snacks and beverages.
We also heard of mixed effects on school group fundraising revenues.  For example an athletic director in one district we reviewed and a school  store manager in another said that they had experienced reduced  revenues from fundraising, which resulted in less money to subsidize  athletic facilities, equipment, uniforms, field trips, and travel for  competition at regional and national events. However, some groups also  mentioned that changing from food to non-food sales can sometimes  increase fundraiser revenues. For example, an athletic director in another  district and a representative of a national association said that other types  of fundraising, such as craft fairs or sales of cards that provide discounts  at local restaurants and other businesses, have raised more money than  candy sales in some districts.
The concerns we heard about competitive food revenues are generally  consistent with those raised by school districts in the past and discussed  by USDA in its interim final regulations. For example, school districts we  visited in 2005 that had taken steps to substitute healthy competitive  foods for less nutritious items expressed strong concerns about potential  revenue losses. However, at that time, the limited data available on  competitive foods revenue from the schools and districts we visited  suggested that districts experienced mixed revenue effects from changes  made to competitive food sales. In USDA’s interim final regulations, the  department acknowledged that there was considerable variation among  schools in the share of their revenue from competitive foods, and some  schools might see substantial reductions in competitive food revenues  after implementation of the federal requirements, at least in the short  term.
At the same time, revenue effects and other challenges related to  implementing the new federal competitive food standards have likely  been mitigated for school groups that received exemptions from the new  requirements for certain fundraisers. School groups are subject to the  same federal competitive food requirements as SFAs, unless exempted;  USDA permits states to determine the allowed frequency of fundraising  exemptions without federal review as long as those sales do not take  place in the food service area during meal times. The eight states we  reviewed varied in the number of fundraising exemptions allowed in  school year 2014-2015, with no fundraiser exemptions allowed in four  states and varied policies on the number exempted and their duration in  the remaining four. For example, during school year 2014-2015, one state  allowed 10 exempted fundraisers per year, per school with each lasting  no longer than 4 consecutive days, while another state allowed unlimited  fundraisers on 36 designated days during the school year. (See table 3.)  Fundraiser exemptions remove challenges some school groups may face  complying with the federal requirements, but they potentially raise other  challenges as well. For example, in 2013 we found that some SFAs were  concerned that these exemptions put the SFA at a competitive  disadvantage relative to other food sales within the school. Further,  some commenters on the interim final regulation raised concerns that  exempt fundraisers threaten the rule’s public health goals and student  participation in the meals programs.
Without a fundraiser exemption, school groups may also sell other food  products that do not comply with the competitive food requirements, on  the school campus 30 minutes after school or in other non-school  locations. In three of eight districts we reviewed, some vending machines  were not turned on until after school. At two schools, we observed sales  of food and beverage products 30 minutes after the end of the school  day, when additional products were sold that did not meet the competitive  food requirements, such as candy, large muffins, pizza, and full-calorie  carbonated drinks. We were told that school groups also continued to  have concession stands at after school sporting and other school events  that sold products that were not subject to the competitive food  requirements. Groups also continued to sell items like candy bars as  fundraisers, providing boxes of candy bars to students that were to be  sold to family, neighbors, and friends outside of school.
section_title: Oversight of Competitive Food Sales has Been Challenging
paragraphs: According to states and SFAs, the involvement of a variety of groups in  competitive food sales at schools has made oversight of competitive food  sales challenging. According to USDA, SFAs are responsible for the  compliance of the sales they operate, and school districts are responsible  for the compliance of foods sold in areas that are outside the control of  the SFA. However, while principals at all of the schools we contacted  were aware of competitive food sales at their schools, our conversations  with them suggested that their involvement with oversight of these sales  varied. For example, 6 of 16 principals said that they or the school  administration must approve fundraisers. Further, 4 school principals told  us that they rely on the SFA director for information about the competitive  food requirements. This is consistent with our conversations with SFA  directors, as five of the eight SFA directors said that they provided  information and assistance regarding the new competitive food  requirements to school administration or school groups and helped  determine product compliance. In one school district, competitive foods  had to be approved by the SFA’s dietitian, and in two other school  districts, the SFA director provided an approved-list of items that could be  sold. However, at the same time, three of eight SFAs expressed  concerns that not all school groups were in compliance with the new  requirements and the consequences for noncompliance were unclear. For  example, one SFA director said that when she observed noncompliant  snacks being sold at schools, she reported it to the principal and  superintendent, but that typically did not result in the noncompliant sales  being shut down permanently. Beginning in school year 2014-2015,  USDA requires that periodic state reviews of schools identify the entities  responsible for selling food and beverages and ensure that such food  meets the competitive food requirements, which should help address  such situations.
During our visits to schools and discussions with SFAs and students, we  found that schools in six of the eight SFAs we reviewed had some  competitive foods for sale during the school day that were not compliant  with the new federal requirements. In some cases, particular items were  out of compliance, such as a sports drink sold a la carte by a SFA that  exceeded the size and calorie requirements, trail mix sold at a school  store that exceeded the calorie and fat requirements, and pizza slices  sold by a school store during lunch that we were told did not meet whole  grain-rich requirements. In other cases, we observed a bake sale in a  school cafeteria during the lunch period, and students told us about  another bake sale held by a teacher in a classroom during the school day  and sales of candy in the library during the school day.
All states we contacted indicated there were challenges in local level  oversight of competitive foods. Officials from three of eight states said  that there is a lack of clarity at the local level about who is responsible for  compliance. Officials from two states said that neither the SFAs nor  school administrators want to be the “food police,” responsible for  overseeing compliance at the local level. Although officials from three  states said that ultimately the superintendent is responsible for the  compliance of school groups’ competitive food sales, not all districts have  yet to work out how this operates at the local level or defined the role of  the SFA director and others. In its interim final regulations, USDA foresaw  issues with ensuring compliance at the local level and said it envisioned  that a school district designee, such as a local school wellness  coordinator, may need to take the lead in this area. USDA also  suggested that sorting through who is responsible for monitoring  competitive foods would initially require planning and cooperation, but if  all parties (i.e., school wellness coordinator, SFA, and school groups)  worked together, such as to share information on allowable foods, the  department believed that implementation in future years would be greatly  streamlined.
The expansion of state oversight responsibility to include reviews of  competitive foods could help ensure compliance with the nutrition  standards, though some states reported that initial oversight of this area  has been challenging. Specifically, beginning in school year 2014-2015,  states are now responsible for overseeing local compliance with both  federal school meals and competitive food requirements, including  providing technical assistance and developing corrective action plans for  SFAs and schools when noncompliance is found. However, officials  from two of eight states told us that their initial oversight of this area  suggests that all school districts do not take competitive food compliance  seriously, and some try to find ways around the requirements. An official  from another state said that there is sometimes resistance to modifying  these sales from principals, especially when competitive food sales may  be the only source of discretionary money for school activities and  equipment. Officials from three of eight states also expressed concerns  that they currently do not have enforcement tools for competitive food  sales, and officials in one state said that they have heard from SFA  directors who do not think that school groups will take compliance with  the requirements seriously unless there are financial consequences.
USDA officials also said that they will be reviewing all aspects of the first  year’s implementation of the competitive food requirements and will  consider any necessary changes before finalizing the competitive food  regulations. When issues of competitive foods noncompliance arise  during state oversight reviews, USDA has said that it sees technical  assistance and training as the first step to address them. However, the  competitive foods interim final regulations also indicate that USDA will  issue a proposed rule to address a number of integrity issues related to  administration of the school meal programs and competitive foods, which  will provide states options for imposing fines against any school or SFA  failing to comply with program regulations.
section_title: USDA’s Assistance Has Included a Substantial Amount of Guidance and Other Efforts
paragraphs: Officials from several states and SFAs that we interviewed during school  year 2014-2015 indicated that USDA’s assistance on the new school  meals and competitive food requirements was helpful or has recently  improved; at the same time, some found the amount of USDA guidance  to be overwhelming. As part of our January 2014 report, we found that all  states found USDA’s guidance and training to be useful as the new  school lunch requirements were implemented during school year 2012- 2013. As implementation of the school meals and competitive food  changes continued during school years 2013-2014 and 2014-2015,  officials from five states and two SFAs who we interviewed in school year  2014-2015 similarly noted that USDA assistance has been helpful. For  example, officials from one state noted that frequent webinars, covering  such topics as menu planning using USDA foods, have been useful. In  addition, two SFAs reported that USDA guidance on the changes has  improved over time; however, a state official also told us that USDA has  issued too much guidance, and it has overwhelmed SFAs. Officials from  three SFAs we spoke with also told us that the amount of guidance they  have received from USDA has been challenging, especially given the  complex nature of the guidance, and one SFA official noted there is not  enough time to read all of the guidance. This difficulty keeping up with the  extensive amount of USDA guidance is consistent with what some states  and SFAs reported to us during school year 2012-2013. In our 2014  report, we found that, in the first 33 months after the Healthy, Hunger- Free Kids Act of 2010 was enacted (from January 2011 through  September 2013), USDA issued about 90 memos to provide guidance to  states and SFAs on the new requirements for the content of school  lunches and paid lunch equity. In the 19 months since then (from  October 2013 through April 2015), we found that USDA issued 51  additional memos related to these changes. In total, USDA has issued  nearly 4,700 pages of guidance on the lunch, breakfast, and competitive  food requirements since the final rule on changes to the lunch and  breakfast content and nutrition standards was issued in January 2012.
With the bulk of the changes to school meals and competitive foods  nutrition standards already required to be implemented, the need for  USDA to issue additional guidance on these changes should diminish in  future years, according to officials. In our 2014 report, we found that  several SFAs reported challenges with the high volume of USDA  guidance that was issued at the same time that they were implementing  significant changes to the lunch program. Similarly, during the 2013-2014  and 2014-2015 school years, SFAs were implementing substantial  program changes—related to breakfast, competitive foods, and whole  grains and sodium for lunch—concurrently with USDA’s issuance of  guidance on those topics. Since the only future planned changes are  additional sodium reductions for school meals and minor changes to  competitive foods, it is likely the amount of USDA guidance will decrease.
Some state and SFA officials we spoke with also found USDA’s  assistance in response to questions about school meals and competitive  food requirements was not always timely or clear. While several state  officials we spoke with said they appreciated USDA’s assistance or had  good working relationships with USDA regional offices, officials from five  of the eight states we spoke with were frustrated by USDA’s response  times. Specifically, officials from two of those states said that USDA  sometimes did not respond to questions for more than a month. Officials  from two states also expressed frustration with the timing of USDA’s  release of guidance surrounding state compliance reviews, as changes  were made after the review cycle began. An official from one of the two  states told us that as a result of the timing, the state was not able to  effectively redesign its electronic records system after it had already been  finalized. In addition, officials from two states and four SFAs also told us  that some of USDA’s guidance was unclear or inconsistent. For example,  one SFA official said that guidance on whether certain a la carte items  meet the competitive foods requirements was difficult to interpret. Two  SFA officials also said that the guidance issued on juice—including how  much can be offered and how frequently it can be offered—has been  confusing. In addition, a state official described frustration with the  multiple modifications of USDA’s guidance surrounding smoothies, which  substantially changed how smoothie components were to be credited  toward the meal pattern. However, not all SFAs we spoke with  highlighted such challenges related to USDA guidance. For example, one  SFA director noted that while one part of the competitive foods guidance  was unclear, the competitive foods requirements are new, and she  expected that USDA would provide clarity. She added that she thought  USDA provided sufficient communications on the new requirements.
In recognition of the challenges SFAs have faced while implementing the  new requirements, USDA has provided other types of assistance  intended to help clarify the regulations and guidance. For example, USDA  partnered with the Institute of Child Nutrition to create the “Team Up For  School Nutrition Success” training and mentoring program, which is  designed for SFAs to share best practices. Also under this program,  experienced SFAs provide targeted technical assistance to those  struggling with certain aspects of implementation to clear up lingering  confusion. In addition, the initiative offers monthly webinars for states and  SFAs on a wide variety of topics—including menu planning and sodium,  which are also made available online for later viewing.
Although USDA has taken some steps toward addressing three of the  four recommendations included in our report and testimony on the school  lunch nutrition changes, the department has not yet acted to address an  issue we reported in our 2013 testimony that would help SFAs meet the  school lunch calorie requirements. Specifically, we found that the gap in  the calorie ranges for the 6-8 and 9-12 grade groups—600-700 and 750- 850, respectively—was problematic for districts we visited that included  schools with students in both groups. In guidance, USDA acknowledged  that the lack of overlap in the calorie ranges for the two grade groups can  be challenging and suggested that districts serve a menu appropriate for  the lower grade level and add a few additional foods for students in the  upper grade level. However, as part of that report we also found that this  may not be a feasible solution for some schools because, for example,  students in different grade ranges may use the same serving lines during  a shared lunch period. In such schools, cashiers at the point-of-sale may  not know each student’s grade level and therefore may not be able to  accurately identify whether lunches comply with requirements. Thus, in  that report we recommended that USDA provide flexibility to help SFAs  with schools that serve students in both grade groups comply with the  defined calorie ranges. While USDA generally agreed with the  recommendation, indicating that it recognizes the need to address the  challenges posed by the lack of overlap in the calorie ranges, the  department has not yet taken action to address the issue.
In the absence of additional USDA assistance in this area, state and SFA  officials we spoke with in school year 2014-2015 described varied  approaches they have taken to address this issue, all of which are  inconsistent with USDA regulations and guidance. For example, one state  official told us that for schools serving meals to students in both grade  ranges, the state recommended serving meals that met the calorie range  associated with the predominant grade group served at each lunch  period. An SFA from another state took a different approach, planning  its menus for these schools to offer lunches with maximum calorie counts  midway between the middle school maximum and the high school  minimum. Officials from another state said that while USDA requirements  do not provide flexibility in this area, and schools with both 6-8 and 9-12  grade groups are supposed to be considered out of compliance if they are  not meeting both calorie ranges, the state has instead chosen to use  common sense when reviewing the menus in such schools. As the  absence of USDA guidance is leading to states making varied decisions  about menu compliance in these schools, we continue to believe that our  June 2013 recommendation to USDA (to provide some flexibility to SFAs  with such schools) continues to have merit and should be fully  implemented.
section_title: Agency Comments
paragraphs: We provided a draft of this report to the U.S. Department of Agriculture for  review and comment. On September 1, 2015, the FNS Director for  Program Monitoring and Operational Support Division, Child Nutrition  Programs, and other FNS officials provided us with their oral comments.  The officials stated that they generally agreed with the report findings.  However, we discussed our previous recommendation that USDA provide  school districts with flexibility to help them comply with the lack of overlap  in the calorie ranges for lunches served to students in grades 6-8 and 9- 12 in schools with both grade groups. As stated in this report, we again  found that some SFAs and states with schools that include students from  both grade groups were taking varied approaches to address the lack of  overlap in the calorie ranges for school lunch, which were inconsistent  with USDA requirements. Officials noted that USDA believes it is  important to maintain the scientifically-based, age-appropriate calorie  ranges and is unlikely to change the calorie requirements. However, they  noted that our findings show an inconsistency in state oversight of  districts with such schools and indicate a continued need for clarification.  The officials said that they intend to continue providing menu planning  guidance and technical assistance to states and districts to help them  comply with these requirements. We continue to believe that additional  flexibility from USDA would assist school district efforts to comply and is  consistent with the Institute of Medicine’s suggestions that USDA and  states should work together to find a solution in these schools, though we  appreciate that additional technical assistance from USDA may also help  achieve this goal.  FNS also provided technical comments on the draft  report, which we have incorporated as appropriate.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution of it until 30 days from  the report date. At that time, we will send copies of this report to the  appropriate congressional committees, the Secretary of Agriculture, and  other interested parties. In addition, this report will be available at no  charge on GAO’s website at http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact me at (202) 512-7215 or brownke@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff who made key contributions to  this report are listed in appendix II.
section_title: Appendix I: Scope and Methodology
subsections: section_title: U.S. Department of Agriculture (USDA)
subsections: section_title: Participation Data
paragraphs: To assess trends in school lunch and breakfast participation, we analyzed  USDA’s national data on meals served in the National School Lunch and  School Breakfast Programs from school year 2000-2001 through school  year 2013-2014. We used the same methodology to assess trends in  participation as we had in our prior report on the initial implementation of  school lunch changes. Each month, states report to USDA on the FNS- 10 form the number of lunches and breakfasts served by category of  student—free, reduced-price, and paid—as well as average daily lunches  and breakfasts served to all students. These data are used to determine  federal reimbursement payments to states. Additionally, in October of  each school year, states report to USDA the total number of students  enrolled in schools with the National School Lunch and School Breakfast  Programs.
Although USDA does not collect additional data on the number of  students participating in the programs each month, the department uses  the lunch and breakfast data it collects to determine the number of  students participating in the programs. Specifically, USDA adjusts the  data on average daily lunches and breakfasts served each month upward  to help account for students who participated in the programs for a  number of days less than all days in the month. To make this adjustment,  USDA uses an estimate of the proportion of students that attend schools  daily nationwide.
To analyze participation in the National School Lunch and School  Breakfast Programs, we reviewed USDA’s data on meals served and  students enrolled, as well as the department’s methodology for  determining student participation, and determined these data and the  method to be sufficiently reliable for the purposes of this report.  Specifically, we interviewed USDA officials to gather information on the  processes they use to ensure the completeness and accuracy of the  school lunch and breakfast data, reviewed related documentation, and  compared the data we received from the department to its published data.  To determine school year participation from these data, both overall and  by free, reduced-price, and paid categories, we relied on 9 months of  data—September through May—for each year.
section_title: Guidance Documents
paragraphs: To understand the scale and scope of assistance USDA has provided to  states and SFAs, we analyzed guidance memos USDA issued from  October 2013 through May 2015. This period allows for a seamless  continuation of the analysis we conducted for the previous study on  implementation of the new nutrition requirements for school lunch, which  reviewed guidance issued from January 2011 through September 2013.  Our intent was to continue our longitudinal review of USDA-issued  guidance addressing implementation of the updated nutrition  requirements, as well as paid lunch equity, and we used the same  methodology that we used for the prior study. Specifically, we reviewed all  guidance memos issued to states during this time period and further  analyzed those that provided guidance addressing the new requirements  for the content of school meals and competitive foods, including related  issues such as food procurement and state review of SFA compliance  with the requirements, as well as those addressing the paid lunch equity  requirements. These memos included the department’s policy and  technical assistance memos, as well as other relevant guidance memos  that were not designated in one of those categories. For guidance memos  that were released in multiple versions, we considered each version to be  a separate piece of guidance. We assessed the number of pages  included in each document, defined as the number of digital pages for  each guidance document, including attachments. In the case of  spreadsheet files, we counted each worksheet within the file as a single  page. We did not conduct an independent legal analysis of these  guidance memos.
section_title: Site Visits
paragraphs: To gather information from the local level on implementation of the new  nutrition requirements for school meals and competitive foods, we  contacted the same eight school districts across the country that we had  visited as part of our prior study of implementation of the new school  lunch requirements in school year 2012-2013. From December 2014  through March 2015, we visited Carlisle Area School District (PA),  Chicago Public Schools (IL), Coeur d’Alene School District (ID), Fairfax  County Public Schools (VA), Irving Independent School District (TX),  Mukwonago Area School District (WI), and Spokane Public Schools  (WA). For the eighth district—Caddo Parish Public Schools (LA)—we  gathered information over the phone from the SFA director and officials  from two schools, as our on-site visit to the district was impeded by  weather-related school closings. We selected these school districts  because they provided variation across geographic location, district size,  and certain characteristics of the student population and district food  services. For example, the proportion of students eligible for free and  reduced-price lunches and the racial and ethnic characteristics of the  student population varied across the districts selected. Further, we  selected districts with different food service approaches, including some  that generally prepared school meals in one central kitchen before  delivering them to schools, some that prepared meals in kitchens on-site  in each school, and others that used alternative approaches for food  preparation. Six of the school districts we contacted managed their own  food service operations, while two districts contracted with food service  management companies. We relied on the U.S. Department of  Education’s Common Core of Data, which provides information on public  schools, to ensure selected districts met several of our criteria. As a  result, all of the districts we selected for site visits were public, although  non-profit private elementary and secondary schools, as well as  residential child care institutions, also participate in the National School  Lunch Program and the School Breakfast Program.
In each of the districts we visited, to gather information on local level  implementation of the new nutrition requirements, we interviewed the SFA  director, as well as other key district-level SFA staff and food service staff  in two schools. During these interviews, we collected information about  lunch and breakfast participation trends; challenges, if any, implementing  the new meal content requirements; challenges, if any, implementing new  nutrition standards for competitive foods; and USDA and state assistance  with the changes. To select the schools we visited in each district, we  worked with the SFA director to ensure the schools included students of  differing grade levels. This allowed us to observe any relevant differences  in their reactions to the new meal and competitive food requirements. In  each school we visited, we observed breakfast and lunch service, as well  as competitive food sales—including students’ food selections,  consumption, and plate waste—and, when feasible, interviewed students  and school staff to obtain their thoughts on the changes. We also  interviewed the eight state child nutrition program directors overseeing  these districts to gather information on statewide lunch and breakfast  participation trends; SFA challenges, if any; and USDA and state  assistance with implementation of the changes. Contacting these districts  and states a second time provides a short-term longitudinal perspective  on challenges related to implementation of the phased-in changes.  However, we cannot generalize our findings from SFAs, districts, and  states beyond those that we contacted.
section_title: Stakeholder and Industry Groups
paragraphs: To gather additional information we interviewed various school nutrition  stakeholder groups, including subject matter experts, professional  organizations, and industry representatives. We selected groups among  those that were involved with school meals, had an interest in children’s  nutrition, and/or were involved in competitive food snacks and beverages,  as well as school fundraisers. This included the School Nutrition  Association (SNA), the National PTA, the Center for Science in the  Public Interest, and other members of the National Alliance for Nutrition  and Activity. We also spoke with the American Beverage Association, the  Snack Food Association, and a group of industry officials who are also  members of SNA.
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Rachel Frisk (Assistant Director),  Dan Meyer (Analyst-in-Charge), Luke Baron, Sara Pelton, and Christine  San made key contributions to this report. Also contributing to this report  were Divya Bali, James Bennett, Jessica Botsford, David Chrisinger,  Aimee Elivert, Kathy Leslie, Theresa Lo, Jean McSween, Steve D. Morris,  Lorin Obler, and Lindsay Read.