School Nutrition:

USDA Has Efforts Underway to Help Address Ongoing Challenges Implementing Changes in Nutrition Standards

GAO-15-656: Published: Sep 14, 2015. Publicly Released: Oct 14, 2015.

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Kay E. Brown
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What GAO Found

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.

Why GAO Did This Study

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.

What GAO Recommends

GAO is not making any recommendations.

For more information, contact Kay E. Brown, (202) 512-7215,

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