Pursuant to a congressional request, GAO reviewed the U.S. Department of Agriculture's (USDA) commodity school districts that received cash subsidies and donated commodities for school lunch programs, focusing on: (1) whether they complied with statutory Buy American requirements; (2) the number of Buy American waivers that the Secretary of Agriculture granted; and (3) the circumstances necessitating the waivers.

GAO found that: (1) USDA and two of the four states reviewed implemented the provisions, but compliance monitoring was limited; (2) although neither USDA nor the states monitored school district food purchases, two of the four school districts periodically inspected food purchases and labels for foreign products; (3) although the regulations permitted waivers from the requirements, neither USDA nor the states received waiver requests from any of the school districts; (4) the act permitted the Secretary to grant waivers for such circumstances as ethnic preferences; and (5) Alaska, Hawaii, and designated U.S. territories were exempt from the requirements.