School Lunch:

Modifications Needed to Some of the New Nutrition Standards

GAO-13-708T: Published: Jun 27, 2013. Publicly Released: Jun 27, 2013.

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Kay E. Brown
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What GAO Found

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.

Why GAO Did This Study

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.

What GAO Recommends

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.

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Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: In January 2014, the U.S. Department of Agriculture issued regulations that remove the requirement for SFAs to comply with the weekly meat/meat alternate and grain maximums for school lunch.

    Recommendation: To improve school food authorities' (SFA) ability to design menus that comply with the new lunch requirements, the Secretary of Agriculture should permanently remove the weekly meat/meat alternate and grain maximums for school lunch defined in federal regulations

    Agency Affected: Department of Agriculture

  2. Status: Open

    Comments: In the GAO report, "School Nutrition: USDA Has Efforts Underway to Help Address Ongoing Challenges Implementing Changes in Nutrition Standards," GAO-15-656, September 14, 2015, we found that the department had not yet acted to provide flexibility to address this prior recommendation. We again found that districts and states took various approaches to address the lack of overlap in calories ranges for schools with students in grades 6-8 and 9-12, and that these approaches were inconsistent with USDA requirements. USDA officials noted that our findings indicate a continued need for clarification and said that they would continue providing menu planning guidance and technical assistance to help states and districts comply with the requirement. In July 2016, USDA reported that it continued to describe its efforts to provide training and technical assistance to states and School Food Authorities (SFA) on meal and calorie requirements. Although we appreciate that additional technical assistance from USDA may be helpful, 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.

    Recommendation: To improve SFAs' ability to design menus that comply with the new lunch requirements, the Secretary of Agriculture should 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.

    Agency Affected: Department of Agriculture


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