School Lunch: Modifications Needed to Some of the New Nutrition Standards
Published: 2013-06-27T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The National School Lunch Program served 31.6 million children in fiscal year 2012, in part through $11.6 billion in federal supports. The most recent reauthorization of the program, the Healthy, Hunger-Free Kids Act of 2010 required that nutrition standards for school lunches be updated. As a result, USDA issued final regulations aimed at providing lunches high in nutrients and low in calories that better meet the dietary needs of school children and required that they be implemented beginning in school year 2012-2013. The new rules provide detailed requirements for meal components--fruits, vegetables, grains, meats, and milk; update requirements for calories, sodium, and fats; and require that each student's lunch contain a fruit or vegetable. To provide information on challenges that school districts have faced, this testimony draws on work GAO conducted as part of its ongoing study of implementation of the changes. Specifically, GAO reviewed relevant federal laws, as well as USDA regulations, guidance, and studies; interviewed USDA officials and groups of food service officials and relevant industry representatives; and visited eight school districts. The districts varied by geographic location, size, and certain student and food services characteristics.
section_title: What GAO Found
paragraphs: School districts faced several challenges implementing the new lunch requirements in school year 2012-2013, according to the eight districts GAO visited and food service and industry officials GAO interviewed from across the country; and the U.S. Department of Agriculture's (USDA) response to some of these challenges has been limited. For example, because USDA regulations restrict the amounts of meats and grains that can be served in school lunches each week, all eight districts GAO visited needed to modify or eliminate popular menu items. These changes sometimes led to negative student reactions. The meat and grain restrictions also led to smaller lunch entrees, making it difficult for some schools to meet minimum calorie requirements for lunches without adding items, such as gelatin, that generally do not improve the nutritional quality of lunches. In response to feedback from states and districts regarding operational challenges caused by the meat and grain restrictions, USDA lifted the limits temporarily, first for the remainder of school year 2012-2013 and then for school year 2013-2014. USDA officials said they did not see a problem making the temporary changes to help with implementation because the limits on meats and grains and the limits on the calories in lunches are somewhat redundant, as both address portion size. However, because the change was seen as temporary, the eight districts GAO visited made only marginal changes to their menus. Rather, several district food services officials, as well as relevant industry representatives, indicated the need for a permanent federal decision on these restrictions, which USDA has also acknowledged.
The calorie range requirements for lunches also challenged some districts, particularly those with schools that include students from both grades 6-8 and 9-12. Because the required lunch calorie ranges for these two grade groups do not overlap, districts with such schools face difficulties planning menus and serving lunches that comply with both requirements. For example, one food services official, whose district includes schools serving 7th through 12th graders, developed menus with calorie counts between the grades 6-8 maximum and the grades 9-12 minimum, leaving the lunches out of compliance with both sets of restrictions. Although USDA has acknowledged that menu planning in such schools can be challenging, USDA's current guidance does not provide these districts flexibility to assist their efforts to comply. Rather, guidance suggests that students from different grades be provided with different lunches, a solution that may be impractical in schools in which students of different grades share lunch periods and serving lines.
Although the eight districts GAO visited expressed support for the improvements to the nutritional quality of school lunch, they reported additional challenges meeting the new requirements, such as student acceptance, food waste, costs, and participation. For example, USDA requires that meals include whole grain-rich products and certain vegetables, but most districts noted that obtaining student acceptance of foods like whole grain pasta and beans has been challenging. If students do not accept these items, the result may be increased food waste or decreased participation in the lunch program, which were concerns in most districts GAO visited. However, student acceptance of the changes will likely improve over time, as indicated by their positive comments about healthy food and consumption of fruits and vegetables in most districts GAO visited.
section_title: What GAO Recommends
paragraphs: GAO recommends that USDA permanently remove the meat and grain maximum requirements and allow flexibility to help districts comply with the lack of overlap in the calorie ranges for grades 6-8 and 9-12 lunches. USDA generally agreed with GAO's recommendations.

section_title: Letter
paragraphs: I am pleased to participate in today’s discussion of school districts’  experiences implementing the new requirements for the National School  Lunch Program. This program served 31.6 million children in fiscal year  2012, supported in part through federal subsidies and commodities  totaling $11.6 billion. Although federal requirements for the content of  school lunches have existed since the program’s creation, the Healthy,  Hunger-Free Kids Act of 2010—the law that most recently reauthorized  school meal programs—required that they be updated by the U.S.  Department of Agriculture (USDA), which administers the National School  Lunch Program. In response, USDA updated requirements for the content  of lunches based on the recommendations of the Institute of Medicine.  USDA issued final regulations defining these new requirements in  January 2012, and required the implementation of many of these  requirements beginning in school year 2012-2013. USDA’s updated  regulations aim to provide lunches high in nutrients and low in calories  that better meet the dietary needs of school children and protect their  health. To that end, the regulations make several changes and additions  to the previous requirements for the content of school lunches, such as  the new requirement that each student’s lunch contain at least one fruit or  vegetable. Under agreements with state agencies, local school food  authorities (SFAs), which are generally aligned with school districts, serve  meals to children in schools and are the entities responsible for  implementing these requirements.
As school year 2012-2013 has progressed, both USDA and the media  have reported that states, SFAs, school officials, parents, and students  have expressed some concerns about the school lunch changes. While  the changes to school lunch are the primary school food changes  required to be implemented in school year 2012-2013, the Healthy,  Hunger-Free Kids Act of 2010 also required similar updates to nutrition  standards for the School Breakfast Program and other foods sold in  schools—or competitive foods—which will be implemented in future  school years. As a result, issues that have arisen because of  implementation of the school lunch changes may have implications for  future changes.
My remarks today will generally address challenges that school districts  faced implementing the new school lunch requirements in school year  2012-2013. This information was gathered using several methods,  including reviews of relevant federal laws, regulations, and guidance;  interviews of USDA officials, a group of eight SFA directors representing  both their own districts and their regions of the country, and a group of  eleven relevant industry representatives; and site visits conducted to  eight school districts across the country. This work was conducted as part  of our current study of implementation of the school lunch changes, in  which we are assessing the extent to which school lunch participation  changed during school year 2012-2013, implementation challenges, and  USDA’s assistance with implementation of the new requirements. Our  site visits were conducted between March and May 2013, and my  remarks represent some of our findings from these visits. 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. For example, we visited districts that generally  prepare school lunches in one central kitchen before delivering them to  schools, districts that prepare lunches in kitchens on-site in each school,  and others that use alternative approaches for lunch preparation. Seven  of the school districts we visited manage their own food service  operations, while one district contracts with food service management  companies. In each district, we met with SFA staff at the district and  school levels, school administrators, and students, and we observed  lunch in at least two schools of different grade levels. We also interviewed  the eight state child nutrition program directors overseeing these districts.  Although both public and non-profit private elementary and secondary  schools, as well as residential child care institutions, participate in the  National School Lunch Program, all of the districts we visited were public.  We cannot generalize our findings from the site visits beyond the school  districts we visited.
My remarks also reflect our reviews of relevant USDA data and studies.  For example, we reviewed USDA’s School Nutrition Dietary Assessment  Study IV (2012), which provides information on school lunches and other  foods sold in schools nationwide in school year 2009-2010. Further,  because it is the basis for USDA’s revised regulations on the content of  school lunches, we reviewed the Institute of Medicine’s report, School  Meals: Building Blocks for Healthy Children (2010). We assessed the  methodologies and findings of the studies we reviewed and determined  that they were sufficiently reliable for the purposes of this testimony.
We conducted this work as part of our ongoing performance audit on  implementation of the new school lunch requirements from February 2013  through June 2013 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 National School Lunch Program, established in 1946, is intended to  safeguard the health and well-being of the nation’s children. The program  provides nutritionally balanced low-cost or free lunches in participating  schools to about 31 million children each month. At the federal level,  USDA’s Food and Nutrition Service oversees the program, which is  administered by states and local SFAs. In fiscal year 2012, the federal  government spent over $11 billion on the National School Lunch  Program. Specifically, USDA provides reimbursement in the form of cash  subsidies and donated commodities based on the number of lunches  served that meet certain federal requirements. Although federal  requirements for the content of school lunches have existed since the  program’s inception, as research has documented changes in the diets of  Americans and the increasing incidence of overweight and obesity in the  U.S., federal lunch requirements have become increasingly focused on  improving the nutritional content of lunches.
The Healthy, Hunger-Free Kids Act of 2010, which most recently  reauthorized the National School Lunch Program, required changes to the  federal lunch requirements with the intention of reducing childhood  obesity and improving children’s diets. Since 1994, federal law has  required SFAs to serve school lunches that are consistent with the  Dietary Guidelines for Americans, and in 2004, federal law required  USDA to issue federal rules providing SFAs with specific  recommendations for lunches consistent with the most recently published  version of the Guidelines. As a result of that requirement, USDA asked  the Institute of Medicine to review the food and nutritional needs of  school-aged children in the United States using the 2005 Dietary  Guidelines for Americans and provide recommended revisions to meal  requirements for the National School Lunch Program. The Institute  published its final report in 2010, and also in that year, the Healthy,  Hunger-Free Kids Act of 2010 required USDA to update the lunch  requirements based on these recommendations. The Institute’s report  recommended changes to the lunch component and nutrition  requirements in place at the time. Regarding the lunch components— fruits, vegetables, grains, meats, and milk—the Institute recommended  offering both fruits and vegetables daily, increasing whole grain-rich  foods, offering only fat-free and low-fat milk, and limiting the amount of  grains and meats/meat alternates served each week. Regarding the  nutrition requirements, the Institute recommended including both  minimum and maximum calorie levels for lunches, increasing the  emphasis on limiting saturated fat and minimizing trans fat, and reducing  sodium content. USDA issued a proposed rule on the new lunch  requirements in January 2011 and a final rule in January 2012. The final  rule required implementation of many of the new lunch requirements  beginning in school year 2012-2013. Since the final rule was issued,  USDA has provided extensive guidance, as well as technical assistance  and training, to states and SFAs to assist with implementation of the new  requirements.
section_title: The Eight SFAs We Visited Faced Several Challenges Implementing the New Lunch Requirements
subsections: section_title: All Were Challenged by Meat and Grain Limits
paragraphs: Because regulations issued in January 2012 by USDA placed limits on  the amounts of meats/meat alternates and grains that can be included in  a school lunch, all eight SFAs we visited modified or eliminated some  popular menu items, leading to negative student reactions in some  districts. USDA’s new regulations specify the minimum and maximum  weekly number of ounces of meats, cheese, or other meat alternates and  the minimum and maximum weekly number of ounces of grains to be  served with lunch, which differ by grade level. In comparison, the  previous regulations only specified the minimum number of ounces of  meats and grains required to be served with lunch each week. (See table  1.) Officials in one of the districts we visited told us that, in response to  the new limits, cheeseburgers were removed from the elementary and  middle school lunch menus because adding cheese to the district’s  burger patties would have made it difficult to stay within the weekly meat  maximums. In another district, the SFA reported that it switched from  using shredded cheese on the chili dog to processed cheese sauce  because it does not count as a meat alternate. A similar type of switch  occurred in one of the districts we visited because of the grain  maximums. That SFA reported that it changed from serving a whole grain  chip to a potato chip because the potato chip did not count as a grain.  The grain maximums also affected popular lunch items, such as  sandwiches. For example, four districts we visited reduced certain grain  options used for sandwiches, such as the sub roll and the tortilla wrap,  and two districts stopped serving peanut butter and jelly sandwiches as a  daily option in elementary schools because the weekly grain maximum  did not allow for a sandwich to be served every day. SFAs in four of the  districts we visited noted that student reactions to these menu item  changes were generally negative, and some said the changes had  impacts on participation, that is, the number of students purchasing  school lunches. For example, the tortilla wrap size change in one district  was followed by a significant decrease in the number of students  selecting their lunches from the previously popular deli sandwich line in  the high schools, as well as a decrease in the overall percentage of  students purchasing school lunches in those schools. Another district’s  change to its sub roll contributed to a middle and high school student  boycott of school lunch that lasted for 3 weeks.
To comply with both the meat and grain maximums and the required  calorie minimums for lunches, some districts added foods that generally  did not improve the nutritional value of lunches. In the new requirements,  USDA specified daily minimum and maximum calorie levels for school  lunches by grade group (K-5, 6-8, and 9-12), which lunch menus must  meet on average over the school week. However, because the entrée,  typically consisting of meat and grain, generally provides the majority of  the calories in the meal, the weekly meat and grain maximums that limit  the size of entrées in effect also limited the calories of the lunches. As a  result, five SFAs we visited reported that the meat and grain maximums  made it difficult to plan menus that met the minimum calorie requirement  for grade 9-12 lunches—750 calories. To comply, some SFAs added  foods to the menus that, while allowable, generally do not improve the  nutritional value of lunches. For example, in three of the districts we  visited, the SFAs reported adding pudding to certain high school menus  to bring the menus into compliance with the calorie minimum. Some SFAs  also added gelatin, ice cream, or condiments such as butter, jelly, ranch  dressing, or cheese sauce to become compliant, according to the districts  we visited and the SFA and industry groups we spoke with. While these  additional menu items provided needed calories to lunches, they also  likely increased the amount of sugar, sodium, or fat in the meal,  potentially undercutting the federal law’s goal of improving the nutritional  quality of lunches.
Some SFAs noted that obtaining meat and grain products from food  vendors that complied with the new requirements was a continual and  evolving process during school year 2012-2013 because vendors were  continually modifying products throughout the year. For example, four  SFAs we visited said they met regularly with vendors during school year  2012-2013 as vendors worked to bring their products into compliance.  One of those SFAs reported working closely with food manufacturers and  vendors throughout the summer of 2012 to find appropriate products,  including a 1.5 ounce burger patty—which is less than half the size of a ¼  pound burger—that allowed the district to continue to serve  cheeseburgers to all students. Representatives from a group of food  manufacturers and other relevant industries we spoke with indicated that  the meat and grain maximums were challenging to respond to in part  because the grain maximums had unexpectedly changed between the  proposed and final rules, and the time between issuance of the final  regulations and required implementation was short. Some noted that  while they were eventually able to reformulate their products to comply  with the new requirements, the process took longer than the 6 months  available between issuance of the final rule and the required  implementation date.
In response to feedback from states and SFAs regarding operational  challenges caused by the meat and grain maximums, USDA lifted the  maximums temporarily. First, in December 2012, USDA issued guidance  allowing states to consider SFAs to be in compliance with the  requirements for school year 2012-2013 if their menus exceeded the  weekly meat and grain maximums. A few months later, in February 2013,  USDA provided the same flexibility for school year 2013-2014,  acknowledging that SFAs needed guidance to help with meal planning  and food procurement for the coming school year, as SFAs often plan  menus and order or contract for food beginning in the winter of the  previous school year. The February guidance also stated that USDA  understands the need for longer term guidance on this issue and is  considering options for addressing the meat and grain maximums beyond  school year 2013-2014. In May 2013, USDA officials told us that the  Department wanted to be responsive to the challenges they had heard  about, and they did not see a problem making the temporary change to  help with implementation because the meat and grain maximums and the  calorie maximums both accomplish the goal of addressing portion size,  making them somewhat redundant. Although this implies that USDA  may permanently remove the meat and grain maximums, USDA officials  told us that the Department is still considering options for a long-term  solution to the meat and grain maximums and has not yet made a  permanent decision.
None of the eight SFAs we visited made substantial changes to their  menus in response to USDA’s temporary removal of the weekly meat and  grain maximums. Reasons that SFAs cited for this decision included: the  flexibility was temporary, districts had already modified their menus to  comply with the new requirements, products were already ordered for  those menus, staff were already trained, and students had been educated  about the new requirements. Instead, those SFAs that made some  modifications after the flexibility was allowed focused on marginal  changes that would ease menu planning and improve student acceptance  of lunches. For example, in the district in which students reacted strongly  to the decreased size of the tortilla wrap for sandwiches, the SFA brought  in a larger wrap, though it was still smaller than the wrap used previously.  Further, in the district that experienced a student boycott of lunch in part  because of the change to the sub roll, the sub roll used in prior school  years returned to the high school lunch menus. In another district that had  decreased the amount of mini corn dogs they provided to each  elementary school student because of the maximums, additional mini  corn dogs were added to each student’s portion.
SFA directors, food manufacturers, and other relevant industry  representatives indicated the need for a timely and permanent federal  decision on these maximums. Specifically, some SFA directors we visited  told us that it is difficult to know how to proceed with menu planning under  the new requirements when the flexibility provided over the maximums  continues to be temporary. The School Nutrition Association, which  represents SFAs across the country, has indicated that it supports the  permanent elimination of the meat and grain maximums, because their  removal will give cafeterias more flexibility to design healthy menus that  meet nutrition standards and student tastes. Although the flexibility exists  for school year 2013-2014, because USDA has given SFAs mixed  messages regarding the Department’s future plans for the meat and grain  maximums, SFAs are currently left guessing about the future outcome,  making planning future budgets and food ordering difficult. Several  industry representatives said that because some SFAs are planning  menus that comply with the maximums, while others are planning menus  that include larger meat and grain portion sizes, industry is experiencing  difficulties forecasting demand, which leads to food production, inventory,  and storage challenges. This situation will soon become more  complicated because of the impending federal changes to the content of  meals served through the School Breakfast Program and other foods sold  in schools.
section_title: Calorie Requirements for Middle and High Schools Also Challenged Some SFAs
paragraphs: Because the required calorie ranges for grades 6-8 and 9-12 do not  overlap, schools with students in both these grade groups faced  challenges complying with the calorie requirements. While the grades K-5  and 6-8 average daily calorie ranges for school lunches overlap at 550- 650 and 600-700, the grades 6-8 and 9-12 ranges, which are 600-700  and 750-850, do not. This creates a challenge for schools that include  students from both grade groups, including schools in two of the districts  we visited. One SFA director, whose district includes schools serving 7th  through 12th graders, noted that complying with both of the calorie range  requirements is particularly difficult when students in different grades use  the same serving lines and share a lunch period. The director noted that  cashiers at the point-of-sale may not know each student’s grade level,  which complicates the accurate identification of a meal that complies with  the requirements. In addition, if certain food items are offered to some  students and not to others depending on their grade, students may react  negatively to the differential treatment. Because of these implementation  issues, this district planned its menus to generally provide 725 calorie  lunches for all students in these schools, which are not in compliance with  either of the required ranges, and could potentially result in fiscal action  against the SFA in the future.
USDA’s response to this issue, provided in part through the Department’s  guidance on menu planning under the new lunch requirements, has been  limited. In the proposed rule on the new lunch requirements, USDA  indicated that the new requirements are expected to bring about positive  outcomes, including simplification of school lunch administration and  operations. However, in comments on the proposed rule, some school  districts expressed concerns that the lack of overlap in the calorie ranges  may lead to increased costs and administrative burden. Although USDA  did not change the ranges in the final rule, in its guidance on the new  requirements, the Department acknowledges that the lack of overlap in  the calorie ranges for these grade groups can be challenging. Because of  this, USDA’s guidance suggests that districts serve a menu appropriate  for the lower grade level and add a few additional foods for students in  the upper grade level. This differs from the previous requirements, which  allowed schools to comply with meal requirements for the predominant  grade group in schools that included students from two different groups.  USDA’s guidance also differs to some extent from the approach  recommended by the Institute of Medicine in its report on which the  federal requirements are based. The report’s authors suggested that, for  schools serving students from multiple grade groups on the same serving  line, the SFA should work with the state agency to find a solution that  ensures the basic elements of the standards for menu planning will be  maintained, including moderate calorie values.
section_title: Student Acceptance Has Been a Challenge to Some Extent
paragraphs: While all eight SFAs we visited expressed support for the goal of  improving the nutritional quality of lunches and felt the new requirements  were moving in that direction, all eight experienced various challenges  related to student acceptance of some of the foods served to comply with  the requirements. Under the new requirements, lunches must include  whole grain-rich products and vegetables from 5 sub-groups each week,  and districts we visited noted that obtaining student acceptance of some  whole grain-rich products and vegetables in the beans and peas  (legumes) and red-orange sub-groups have been challenging. For  example, six districts mentioned student acceptance of whole grain  breads or pasta as being a challenge. Regarding vegetable sub-groups,  five districts we visited said that they have had difficulty obtaining student  acceptance of the beans and peas (legumes) sub-group, and two districts  expressed difficulty with sweet potatoes, in the red-orange sub-group.  Some noted that they have continued to try new recipes throughout the  year to address these challenges, but acceptance has been limited.  Challenges with student acceptance of these foods were foreseen by the  Institute of Medicine in its report recommending they be required  components of school lunch, as national data showed that few students  reported eating these types of foods. The researchers noted that  implementation of effective educational, marketing, and food preparation  strategies, as well as the increased availability of suitable and appetizing  products, may improve student acceptance of these foods.
Some districts reported that, if the past is an indicator, student  acceptance of these foods may improve over time, and student  comments regarding other healthy foods they like suggest this as well. In  four of the districts we visited, SFA directors noted that they had begun  adding whole grains into their menus before the current school year, and  they have seen student acceptance of whole grain products improve over  time. In addition, one district’s SFA director also noted that acceptance of  foods in the beans and peas (legumes) sub-group has improved over  time. When we talked to students in the schools we visited and asked  them about lunch foods they do not like, these specific foods were  mentioned by some students in four of the eight districts, but most  students focused their comments on other vegetables or specific entrees.  Further, most of the students we talked to indicated that they like to eat  healthy and nutritious foods, and they think that school lunches generally  provide such foods. Although school year 2012-2013 is the first year that  students were required to take a fruit or a vegetable with school lunch  nationwide, when we asked students what they like about school lunch  this year, students in 13 of the 17 schools we visited to observe lunch  reported liking certain fruit and vegetable options.
Food waste is also an indicator of lack of student acceptance of the new  lunch requirements. Students may take the food components they are  required to as part of the school lunch, but they may then choose not to  consume them. Although none of the districts we visited had fully  analyzed food waste over the past few years to determine if it changed  during school year 2012-2013, six of the SFAs we visited told us they  believe food waste has increased because of the new lunch  requirements. In particular, SFAs said that the fruits and vegetables  students are now required to take sometimes end up thrown away, and in  our lunch period observations in 7 of 17 schools, we saw many students  throw some or all of their fruits and vegetables away. However, at the  same time, we observed other students take and consume sizable  quantities of fruits and vegetables and the other lunch components in the  remaining 10 schools in which we observed lunch, resulting in minimal  food waste. Four of the SFAs we visited talked about food waste being  more of an issue with the youngest elementary school students, possibly  because of the amount of food served with the lunch and the amount of  time they have to consume it. The Institute of Medicine report  acknowledged differences in food intake among elementary students,  noting that the amounts of food offered under the new recommendations  may be too large for some of the younger elementary school children  because they are more likely to have lower energy needs than the older  children in the same grade group. In USDA’s final rule, the Department  discussed the offer versus serve policy, which has been required for  senior high schools and optional for all other schools since 1975, as a  way to minimize food waste. Under the current regulations, this policy  allows students to decline two of the five meal components offered with  the lunch, rather than requiring students to be served all five  components. However, the SFA director in one of the districts we visited  noted that the district has chosen not to implement the offer versus serve  policy for the youngest students because they have difficulty making  choices, which extends the time spent in the serving line and decreases  the time students have to consume their lunch.
Student participation in lunch has decreased to some extent in school  year 2012-2013, which is another indicator that student acceptance of  school lunches may have declined since the changes. Most of the SFAs  we visited reported that they experienced decreases in lunch participation  in school year 2012-2013 in part because of the new lunch requirements  and other factors. USDA’s national data, which do not account for  adjustments related to changes in monthly serving days or student  enrollment across years, also generally show that student lunch  participation was lower in school year 2012-2013 than it was the year  before. Later this year, when we complete our study of the school lunch  changes, we plan to provide additional information on lunch participation  trends.
section_title: SFAs Faced Other Challenges, Including Hunger Concerns and Increased Costs
paragraphs: SFAs also faced concerns in school year 2012-2013 that the new lunch  requirements were leaving some students hungry—an issue raised in five  of the districts we visited. For example, in one district, a high school  principal told us that during school year 2012-2013, athletic coaches  expressed concerns that student athletes were hungrier after school than  they were in previous years, and staff reported that more students were  distracted during the final period of the school day than in previous years.  In the district we visited in which middle and high school students  boycotted school lunch at the beginning of the year, the boycott was led  by two student athletes in part because they indicated that the lunches  were leaving them hungry. These concerns were likely related to  decreased entrée sizes. During our visits to schools, students in six  schools mentioned that they have been hungry this year after eating  school lunch because of various reasons. For example, students in three  schools attributed this to the smaller entrees, and students in one of those  schools also noted that it may be related to the timing of their lunch  periods, as their school’s first lunch period began around 10:30 a.m. and  the school day ended at about 2:30 p.m. In another school, students  acknowledged that they had not taken or eaten all of the items offered  with the lunch, which we observed resulted in a smaller sized lunch. (See  figure 1.) In contrast, when students served themselves all of the lunch  components in the districts that we visited, their lunches were  substantially larger in size, primarily because of the large amounts of  fruits and vegetables they selected. (See figure 2.)
School lunches generally provide fewer calories under the new  requirements than in past years, likely because of smaller entrée sizes.  Specifically, the new required lunch calorie maximums for each grade  group are either lower or comparable to the calorie minimums previously  required. As a result, school lunches generally provided more calories in  the past, according to national data, than they are allowed to in school  year 2012-2013, particularly for younger students. Although the  previous nutrition standards were developed to align school lunches with  the Dietary Guidelines for Americans, they were developed in the mid  1990s. Since then, the percentage of children who are overweight and  obese has increased, and research has shown that excess food  consumption, poor food choices, and decreased physical activity  contribute to these trends. The Institute of Medicine’s 2010  recommendations for the lunch pattern were developed using a data- based approach, which assessed data on healthy weights and heights,  physical activity, and the distribution of calories among meals, and the  authors indicate that the recommended lunches are appropriate for the  level of physical activity of most children.
SFAs also expressed concerns about the impact of compliance with the  new lunch requirements on food costs and their budgets. All eight SFAs  we visited reported that they have incurred increases in fruit and  vegetable costs this year because of the requirement that students take  at least one fruit or vegetable with lunch. Further, most indicated that  overall costs for school lunch were greater in school year 2012-2013 than  in the past, and three expressed concerns about the impact of these  changes on their overall financial stability. Because we conducted our  visits before the end of the school year, we have not yet obtained data  from these SFAs on how they ended the year financially, though we plan  to provide information on those results in our final report.
All eight SFAs we visited also discussed other challenges implementing  the lunch changes during school year 2012-2013, such as additional  menu planning issues, food procurement, new requirements related to the  price of lunches, the pace of implementation, and USDA’s assistance with  the changes. When we complete our study of the lunch changes later this  year, we will provide additional information about implementation  challenges and USDA’s assistance to states and SFAs with  implementation.
section_title: SFAs Noted Concerns about the Proposed Competitive Foods Changes
paragraphs: In addition to the school lunch changes, the Healthy Hunger-Free Kids  Act of 2010 required that USDA specify and require nutrition standards for  all foods and beverages sold outside the school meals programs on the  school campus during the school day, which are commonly referred to as  competitive foods because they compete with school meal programs.  Competitive foods are often sold through vending machines, school  stores, and fundraisers, and also include SFA sales of a la carte items in  the cafeteria. In school year 2009-2010, competitive foods were sold in an  estimated 93 percent of schools nationwide, according to a recent USDA  study. The proposed rule containing these standards was published by  USDA in February 2013, and during our visits to SFAs, many expressed  concerns that certain aspects of the proposed rule would be challenging  to implement, if finalized.
Specifically, seven of the eight SFAs we visited expressed concerns  about what they viewed as a lack of clarity in the proposed rule regarding  how the nutrition standards for competitive food sales administered by  entities other than the SFA will be enforced. In our 2005 report on  competitive foods, we found that many different people made decisions  about competitive food sales, but no one person commonly had  responsibility for all sales in a school. At that time, in a majority of schools  nationwide, district officials made competitive food policies, while SFA  directors and principals made decisions about specific sales. Other  groups, such as student clubs and booster groups, also made competitive  food decisions through their direct involvement in sales. The number and  variety of groups involved in these sales typically increased as the school  level increased. For example, an estimated 48 percent of middle schools  nationwide had three or more groups involved in these sales compared to  an estimated 83 percent of high schools. Although a 2004 law required  districts to implement wellness policies in school year 2006-2007 that  addressed nutritional guidelines for all foods available in schools during  the school day, some of the SFAs we recently visited told us that these  policies have generally not been enforced, in part because no one person  was granted enforcement responsibility over all such sales.
SFAs we visited also expressed concern that the proposed rule’s  inclusion of differing nutrition standards based on the type of competitive  foods sale will put the SFA at a competitive disadvantage relative to other  food sales within a school. For example, five SFA directors expressed  concerns about the proposed rule’s provision allowing states discretion to  make decisions about fundraisers that are exempt from the federal  nutrition standards for competitive foods. Some SFA directors expressed  concerns that this would potentially result in inconsistent treatment,  whereby SFAs’ competitive food sales would be required to follow the  nutrition standards and fundraisers would not. Similarly, some SFAs  expressed concerns about the proposed rule’s inclusion of different  standards for beverages sold in food service areas during meal periods— which are typically sold through SFA a la carte sales—and beverages  sold outside of meal service areas—such as those through vending  machines. Specifically, although the proposed rule allows the sale of milk,  water, and juice through any competitive food venue at any time, the rule  also allows the sale of other beverages, except for in food service areas  during meal periods. However, this restriction is somewhat similar to the  current federal requirements on competitive food sales.
section_title: Conclusions
paragraphs: Across the country, more nutritious school lunches likely were provided to  students during school year 2012-2013. All eight SFAs we visited  expressed support for the goal of improving the nutritional quality of  lunches and felt the new federal requirements were moving in that  direction. Many students’ positive comments on healthy foods, their views  that school lunches generally provide such foods, and their consumption  of sizeable quantities of fruits and vegetables in the majority of schools  we visited indicate that acceptance of the new lunch requirements will  improve over time. However, as the first year of implementation of the  new requirements for the content of school lunches has unfolded, the  SFAs we visited also faced a variety of challenges.
While some of the challenges SFAs faced this year have been addressed  and others may become less difficult as time elapses, those caused by  the required weekly maximum amounts of meats and grains permitted in  lunches and the lack of overlap in the allowable calorie ranges for grades  6-8 and 9-12 likely will not. Because of the meat and grain maximums,  some districts made menu decisions that are inconsistent with the goal of  improving children’s diets, as they added desserts and condiments that  increased the amount of sugar, salt, or fat in lunches in order to comply  with the required calorie minimums. Acknowledging that the meat and  grain maximums created challenges for SFAs, USDA lifted them through  school year 2013-2014 and indicated that the maximums may not be  needed to accomplish the nutrition goals of the new requirements.  However, although USDA has acknowledged the need for a permanent  decision on the maximums, they have yet to provide one, hindering the  ability of school districts to plan menus, food purchases, budgets, staff  training, and student education because they do not know whether the  meat and grain restrictions will be reinstated in the future or not. In  addition, the requirements that lunches served to students in grades 6-8  provide different amounts of calories than lunches served to students in  grades 9-12—even in schools that serve students in both grade groups— is inconsistent with past practices, expert recommendations, and USDA’s  intent of simplifying the administration and operations of the school lunch  program. Most significantly, the inflexibility of these calorie requirements  substantially hinders certain SFAs’ ability to comply, which may  potentially result in fiscal action against SFAs in future years. Absent a  permanent USDA decision to remove the meat and grain maximums and  increase flexibility for schools that serve meals to students in both the 6-8  and 9-12 grade groupings, SFAs will continue to face challenges  implementing the regulations, potentially impeding their efforts to meet  their key goals—healthier foods in school for healthier students.
section_title: Recommendations
paragraphs: To improve SFAs’ ability to design menus that comply with the new lunch  requirements, we recommend that the Secretary of Agriculture: permanently remove the weekly meat/meat alternate and grain  maximums for school lunch defined in federal regulations, and modify federal regulations or guidance to allow school districts  flexibility in complying with the defined calorie ranges for schools with  students in both the grades 6-8 and 9-12 groups.
We provided a draft of this testimony to USDA for review and comment.  In oral comments, USDA officials indicated that they generally agreed  with our recommendation regarding meats and grains, and they are  currently developing an approach for permanently lifting the meat and  grain maximums. Officials added that while they recognize the need to  address the challenges posed by lack of overlap in the calorie ranges for  grades 6-8 and 9-12, it is important to identify a solution to this issue that  ensures calorie ranges remain appropriately targeted to students based  on their ages—a point emphasized by the Institute of Medicine. USDA  officials also said that they have been collecting information on  implementation of the new lunch requirements throughout the year from  many school districts and have heard about implementation challenges.  However, according to USDA officials, official reporting by states  indicates that a majority of districts have been able to comply with the  new requirements. USDA also expressed concern that the findings in the  testimony did not reflect a nationally representative sample of school  districts. We continue to believe that our site visits to eight school districts  and our interviews with eight SFA directors from across the country, state  officials, and industry representatives enabled us to identify some of the  challenges school districts are facing in implementing the new nutrition  standards. Our final report will provide additional information and data to  inform these issues.
Chairman Rokita and Members of the Subcommittee, this concludes my  statement. I would be pleased to respond to questions you may have.
section_title: Contacts and Staff Acknowledgments
paragraphs: For further questions on this testimony, 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 statement. Individuals who made key contributions to this  statement include Jessica Botsford, Robert Campbell, Rachel Frisk,  Kathy Larin, Jean McSween, Dan Meyer, and Zachary Sivo.
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