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Report to Congressional Requesters:

United States General Accounting Office:

GAO:

May 2003:

SCHOOL LUNCH PROGRAM:

Efforts Needed to Improve Nutrition and Encourage Healthy Eating:

GAO-03-506:

GAO Highlights:

Highlights of GAO-03-506, a report to Congressional Requesters 

Why GAO Did This Study:

Recent trends in children’s health and eating habits are alarming.  
Over 15 percent of children are overweight—double the rate in 1980. 
Children’s diets are high in fat but low in fruits, vegetables, and 
other nutritious foods. The National School Lunch Program has had a 
continuing role in providing students with nutritious meals. However, 
serving the meals is only the first step.  Students must choose to eat 
the nutritious food and limit the less healthful choices. GAO was 
asked to report on the extent to which school lunches, nationwide, 
were meeting nutrition standards, and schools were encouraging healthy 
eating, what barriers selected schools faced in accomplishing this, 
and what innovative steps they had taken to overcome the barriers.

What GAO Found:

Schools are moving toward meeting school lunch nutrition requirements, 
but more improvements are needed. According to national studies, 
lunches meet requirements for nutrients such as protein, vitamins, 
calcium, and iron, but do not meet the required 30 percent limit for 
calories from fat. Also, efforts to encourage healthy eating could be 
increased. Students may need more exposure to nutrition education to 
effect positive changes in their behavior, and most students have 
access to foods of little nutritional value, such as soft drinks and 
candy, at school.

In schools we visited, barriers to providing nutritious meals and 
encouraging healthy eating included budget pressures and competing 
time demands. Regarding providing nutritious food, officials said when 
they introduce healthier foods, they take the risk that students will 
buy fewer school lunches resulting in loss of needed revenue. 
Regarding encouraging healthy eating, officials said the focus on 
meeting state academic standards limited time to teach nutrition. 
Also, schools paid for special activities or other items not covered 
in the school’s budget with profits from vending machines and snack 
bar sales.

Schools had taken a variety of innovative steps to overcome barriers.  
With respect to providing nutritious food, while minimizing the risk 
students might reject healthier choices, schools modified recipes to 
lower the fat content of popular foods such as pizza and conducted 
taste tests before adding healthier choices. To encourage healthy 
eating, schools found time to teach nutrition by integrating nutrition 
lessons into reading and math classes, and some established school 
food policies to restrict unhealthy choices. Some schools enlisted 
help from parents, community organizations, and businesses. Officials 
noted that overcoming barriers required strong and persevering 
leadership.

What GAO Recommends:

GAO recommends that the Secretaries of Agriculture, Health and Human 
Services, and Education work together to identify specific strategies 
to help schools promote nutrition education while meeting the demands 
of state academic standards and to encourage each state to identify a 
focal point to promote collaborative efforts that would further 
develop nutrition education activities for schools.  

www.gao.gov/cgi-bin/getrpt?GAO-03-506.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact David D. Bellis at (415) 904-2272.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Schools Moving Toward Meeting Nutrition Requirements, but Improvements 
Needed:

Barriers Exist to Providing Nutritious Food and Encouraging Healthy 
Eating Choices:

Schools Have Implemented Approaches to Overcome Barriers:

Conclusions:

Recommendations for Executive Action:

Agency Comments:

Appendix I: Comments from the Department of Health and 
Human Services:

Appendix II: Comments from the Department of Education:

Appendix III: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Tables:

Table 1: Mean Nutrient and Caloric Content of School Lunches Offered in 
School Year 1998-99 and School Year 1991-92 Compared with NSLP 
Standards:

Table 2: Percentage of Schools Offering Selected Foods in Competition 
with School Lunches:

Abbreviations:

CDC: Centers for Disease Control and Prevention
MOU: Memorandum of Understanding
NSLP: National School Lunch Program
SFA: School Food Authority
SNDA: School Nutrition Dietary Assessment Study
SHPPS: School Health Policies and Programs Study
USDA: United States Department of Agriculture:

United States General Accounting Office:

Washington, DC 20548:

May 9, 2003:

The Honorable Tom Harkin
Ranking Minority Member
Committee on Agriculture, Nutrition, and Forestry
United States Senate:

The Honorable Richard G. Lugar
United States Senate:

The nation faces a complex challenge in addressing recent trends in 
children's health and eating habits. The percentage of children ages 6 
to 
19 who are overweight has more than doubled to over 15 percent since 
1980, and the incidence of Type II diabetes--closely associated with 
obesity--has also increased in the past decade. Children's diets are 
too high in fat but low in fruits, vegetables, and other foods that 
provide needed nutrients, according to the U.S. Department of 
Agriculture (USDA). At the same time, a recent study reported that, in 
2001, nearly one-half million children lived in households in which one 
or more children were hungry at some time during the year because the 
household lacked money enough for food.[Footnote 1] Healthy eating 
patterns in childhood are important to promote optimal intellectual 
development and prevent health problems.

The National School Lunch Program has played a continuing role in 
school-based efforts to provide students with nutritionally balanced 
meals at low or no cost. In fiscal year 2002, about 28 million children 
each day at about 99,000 public and nonprofit schools and residential 
child care institutions received meals through this program. USDA's 
Food and Nutrition Service administers the program at the federal 
level, and state education agencies typically administer and monitor 
the program through agreements with local school food authorities--
offices responsible for managing the school meals program in one or 
more schools. School food authorities that choose to participate are 
federally subsidized for each meal they serve. To be reimbursable, 
meals must meet certain nutritional requirements. However, serving 
nutritious lunches and other meals is only the first step in promoting 
a healthy school food environment. Students must choose to eat the 
nutritious meals as well as limit the other less healthful food they 
may eat during the day.

Because of your concern about the serious diet-related health problems 
faced by the nation's children and the role of school lunches in 
addressing the problems, you asked us to answer the following 
questions: (1) What is known nationally about the extent to which 
schools and school food authorities are meeting USDA nutrition 
requirements and promoting healthy eating among students? (2) What 
barriers do schools and school food authorities face in serving 
nutritious food and encouraging students to make healthy eating 
choices? (3) What steps have schools and school food authorities taken 
to overcome the barriers to serving nutritious food and encouraging 
students to make healthy eating choices? We are also issuing two other 
related reports--one concerns keeping school meals safe from food borne 
illness and the other addresses the cost of school meals.[Footnote 2]

To report on the extent to which schools are meeting USDA nutrition 
requirements and promoting healthy eating among students, we relied 
primarily on the findings of three national studies[Footnote 3] 
considered to be authoritative by researchers and other experts in the 
field. A statistician and a social scientist examined each study to 
assess the adequacy of the samples and measures employed, the 
reasonableness and rigor of the statistical techniques used to analyze 
them, and the validity of the results and conclusions that were drawn 
from the analyses. To report on the barriers schools face and the 
efforts schools and districts have made to overcome the barriers to 
serving nutritious food and encouraging healthy eating choices, we 
reviewed the literature and consulted with experts in the school lunch 
program and child nutrition area. On the basis of recommendations from 
these sources, we identified and selected states for site visits that 
were recognized leaders in the area, schools that had approaches 
already in place, and schools that had not yet fully implemented such 
efforts. We selected schools for site visits that represented a range 
of the following characteristics: school district size, locale (rural, 
urban, or suburban), type of school (elementary and secondary), and 
percent of students eligible for free or reduced price meals. We 
conducted on-site reviews of school lunch activities at 
22 schools in California, Kentucky, Michigan, Rhode Island, and 
Texas.[Footnote 4] We discussed state operations and activities with 
officials in each state. In each school district, we discussed efforts 
and barriers to providing nutritious food and encouraging healthy 
eating choices with school food authority officials, food service site 
managers, school principals, and teachers. At some locations, we also 
discussed efforts with students and parents. We conducted our study 
from August 2002 to March 2003 in accordance with generally accepted 
government auditing standards.

Results in Brief:

Schools have made significant progress in meeting USDA nutrition 
requirements since the mid-1990s but need to make improvements both in 
meeting the nutrition requirements and in promoting students' healthy 
eating choices, according to national studies of school lunches. 
Regarding nutrition requirements, the studies found that in 1991-92 and 
1998-99, the average school lunch exceeded the required amount of 
nutrients, such as protein, vitamins A and C, and calcium. 
Additionally, schools have reduced the average proportion of calories 
from fat in lunches from 38 to 
34 percent, nationwide, during this period. However, more than three-
quarters of schools have not yet achieved the required rate of no more 
than 30 percent. Regarding encouraging healthy eating, a national study 
of nutrition education in kindergarten through fifth grade found that 
nutrition is taught by most teachers. However, studies suggest, not 
enough to show an impact on children's behavior. Moreover, national 
studies also noted that even when at school, students had access to 
food from a number of sources other than the meals that are regulated 
by USDA's programs. For example, students at most secondary schools and 
many elementary schools can purchase foods and beverages of limited 
nutritional value from vending machines and school stores.

Some school and school food authority officials in the 22 schools we 
visited cited barriers they faced in improving the nutritional quality 
of their lunches; however, many we spoke with expressed greater concern 
over the barriers to promoting healthy eating among students. In regard 
to improving the nutritional quality of lunches, many officials cited a 
barrier that was financial rather than dietary. They said that when 
school food authorities introduce healthier foods with lower fat 
content they take the risk that students will not like the menu changes 
and will buy fewer school lunches. Because school food authorities 
operate their programs on a break-even financial basis, and student 
meal payments make up a large part of their revenue, a decrease in 
meals purchased can throw their budget out of balance, officials said. 
With respect to encouraging healthy student eating habits, many 
teachers and school officials told us that their ability to place more 
emphasis on teaching nutrition and good dietary habits was limited by 
the increased focus on devoting class time to the subject matter needed 
to meet state academic standards. Officials also said that they face 
barriers to restricting student in-school access to foods of limited 
nutritional value. For example, many school principals and 
organizations told us they receive money from vending machines and 
sales of other food and beverages that may be of limited nutritional 
value. They said it is difficult to limit these sales because the funds 
are often used to pay for special activities or items not covered in 
the school's budget. Similarly, school food authority officials told us 
that to help manage their budgets, they have chosen to sell less 
healthful items in the cafeteria, in competition with the USDA 
reimbursable meals.

Many of the schools and districts we visited had taken steps to 
overcome such barriers. To improve nutritional quality while minimizing 
the risk that students would reject healthier choices, some schools 
developed recipes and techniques that lowered the fat and sodium 
content of popular foods such as pizza and enchiladas without 
sacrificing the appeal of these items. Some schools conducted student 
taste tests before they added new and healthier choices such as yogurt 
and salads. To encourage healthy eating, some schools changed their 
cafeteria layout and offered more healthy choices--for example, 
offering lunch stations or lines with different themes, such as soup 
and salad or deli sandwich selections. To expand students' 
opportunities to learn about healthy eating despite limited class time, 
some schools integrated nutrition education into the existing reading 
and math curricula and displayed nutrition bulletin boards. To restrict 
other, less healthy food choices, a few schools had established a 
school food policy that, for example, limited certain vending machine 
items or improved the nutritional quality of foods on school grounds. 
Finally, some schools had devised a broader approach that reached 
beyond the school to enlist help from parents, community organizations, 
and businesses. Together, they sponsored health fairs and organized 
health-related family activities to raise nutrition awareness. 
Officials told us that their efforts to overcome barriers and make any 
change--particularly involving collaboration on a school or community 
wide level--required strong and persevering local leadership with a 
focus on nutrition and healthy eating. Leadership at the state level 
was also viewed as valuable.

In support of such efforts, USDA and the Departments of Health and 
Human Services and Education have recently signed a memorandum of 
understanding--an important step in establishing a partnership to 
address student nutrition and other health-related issues. We recommend 
that the agencies, using the partnership as a foundation, identify 
specific strategies and develop materials to help schools promote 
nutrition education while also meeting the requirements of state 
academic standards. We further recommend that the agencies, working 
together through the memorandum of understanding, encourage states to 
identify a focal point in each state to promote collaborative efforts 
that would further develop nutrition education activities for the 
schools.

We received oral comments on this report from USDA and written comments 
from the Departments of Health and Human Services and Education. The 
agencies generally agreed with the report and recommendations. However, 
the Department of Education expressed concern that the information we 
present appears to imply that accountability provisions in the No Child 
Left Behind Act may contribute to compromising a healthy eating 
environment in schools. We believe that nutrition education and other 
components of a healthy eating environment can and should be compatible 
with schools' efforts to meet the requirements of state academic 
standards. It is for this reason that we recommended that federal 
agencies work together to help schools promote nutrition education and 
healthy eating among students. See appendixes I and II for the written 
comments.

Background:

The National School Lunch Program (NSLP), established in 1946 and 
amended many times, provides nutritionally balanced, low-cost or free 
meals to children throughout the United States. Over 180 billion 
lunches have been served since the program's inception. USDA's Food and 
Nutrition Service, state agencies--usually departments of education--
and school food authorities (SFAs) all play a role in managing the 
program. SFAs that choose to take part in the program are reimbursed 
with cash subsidies and receive donated commodities from USDA. In 
return, they must serve lunches that meet federal requirements and 
offer free or reduced price lunches to eligible children. The federal 
government reimburses the states, which in turn reimburse SFAs for each 
meal served.[Footnote 5] In fiscal year 2001, the federal government 
spent over $6 billion in cash reimbursements and commodities for school 
lunches. To ensure nutritional quality, regulations developed under the 
National School Lunch Act initially required schools to include 
specific serving sizes of food such as fruits, vegetables, and whole 
milk in school lunches. In 1994, Congress amended NSLP requirements 
with the Healthy Meals for Healthy Americans Act[Footnote 6] to require 
schools to serve meals that adhere to Dietary Guidelines for Americans, 
which include limits on total fat and saturated fat. Additionally, 
school meals must meet one-third the recommended daily allowance for 
calories and for nutrients such as protein, calcium, iron, and vitamins 
A and C. Compliance with the standards is determined by averaging the 
nutritional content of the lunches offered over a school week.

SFAs have flexibility in operating their school meal programs. They may 
operate the programs themselves or contract with food service 
management companies to perform functions such as planning and 
preparing menus and selecting and buying food. All or some food 
preparation may occur at on-site school kitchens or at central 
kitchens, which distribute food to satellite schools. In addition, SFAs 
select one of five menu-planning approaches they use to comply with 
nutritional requirements: two food-based, two nutrient-based--as well 
as a fifth option for "any reasonable approach." In a food-based 
approach, SFAs plan meals to include minimum quantities of five meal 
pattern items (i.e., milk, meat or meat alternative, two different 
servings of vegetables and/or fruits, and bread or grain products). In 
a nutrient-based approach, SFAs prepare a computerized nutritional 
analysis of the week's menu to ensure that the meals meet nutritional 
requirements. Schools that use a nutrient-based approach are required 
to serve milk and to offer at least one entrée and one side dish.

To increase student participation and reduce waste, an "offer vs. 
serve" provision in NSLP was introduced. Previously, for reimbursable 
lunches, the entire meal package was served to students. Under the new 
provision, schools offer foods that meet nutrient requirements and 
encourage students to take them. Students are not required to take all 
menu items, but must select specific menu items for a meal to be 
reimbursed. For example, in SFAs that use a food-based menu planning 
system, students must take a full portion of a least three of five 
meal-pattern items offered for a lunch to be reimbursable. In SFAs that 
use a nutrient-based system and offer the minimum of three menu items, 
students must select at least two of the USDA meal-pattern items 
offered, one of which must be an entrée. If more than three menu items 
are offered, students may decline a maximum of two menu items, however, 
the entrée may not be declined. SFAs are required to use the offer vs. 
serve provision for senior high school students, and they have the 
discretion to use the provision for elementary and middle school 
students.

NSLP requires state agencies to conduct periodic evaluations of SFA 
compliance with nutritional and other requirements. State agencies 
often review SFA compliance with the School Meals Initiative in 
conjunction with the broader-based administrative reviews called 
Coordinated Review Efforts that are conducted every 5 years. The 
procedures followed in conducting School Meals Initiative reviews 
depend upon the menu planning system used by the SFA. For SFAs using 
food-based menu planning systems, the state agency must conduct its own 
nutrient analysis of the menu served during the review period. For SFAs 
using nutrient-based systems, the state agency reviews the menus and 
production records and assesses the SFA's nutrient analysis for a 1-
week period, which can be any week of the current school year prior to 
the period of review.

SFAs and schools may allow the sale of food in addition to meals served 
through NSLP. Under USDA regulations, these foods are considered 
"competitive foods" if they are sold in competition with lunches served 
under the program in food service areas during the lunch periods. 
Competitive foods may also include foods and beverages purchased from 
vending machines, school stores, and snack bars. The regulations 
provide the states and SFAs with discretion as to whether to impose 
restrictions on the sale of all foods, such as by limiting the time or 
locations of the sales. However, under the regulations, the schools 
must prohibit the sale of "foods of minimal nutritional value" in the 
school cafeteria during meal periods. The federal regulations do not, 
however, prohibit the sale of foods of minimal nutritional value 
outside the cafeteria any time during the school day.[Footnote 7] Foods 
of minimal nutritional value are defined in federal regulations and 
include, for example, carbonated soft drinks, chewing gum, and 
marshmallow candies.

In addition to providing assistance in meeting nutrition requirements, 
USDA's Food and Nutrition Service established the Team Nutrition 
initiative in 1995 to develop and disseminate a package of materials 
that encourage healthy eating and physical activity among students. 
These materials focus on the benefits of good nutrition and motivating 
students to change their behavior. Additionally, Team Nutrition 
provides grants to states and technical assistance materials for school 
food service personnel and classroom nutrition education materials as 
well as guidance and materials on how to build school and community 
support for healthy eating, physical activity, and a healthy school 
nutrition environment. The initiative has its own Web site and recently 
began an electronic newsletter to food service personnel as another 
channel to share ideas for implementing activities and concepts at 
state and local levels. Changing the Scene and Eat Smart-Play Hard, two 
additional USDA initiatives that provide resources to promote healthy 
eating and physical activity are also available to schools. 
Additionally, the Department of Health and Human Services' Centers for 
Disease Control and Prevention (CDC) has developed and disseminated a 
variety of materials and information to help schools implement efforts 
to address health issues, including nutrition and physical activity. 
CDC has also provided funding to promote healthy eating and physical 
activity. For example, in 2000, CDC initiated a grant program to 
support state health departments in developing and implementing 
nutrition and physical activity interventions. In 2003, CDC provided 
support for coordinated school health programs in 22 states that 
focused on promoting healthy eating behaviors, physical activity, and 
tobacco use prevention among students. Finally, the role of schools and 
the community in addressing the national problem of child obesity is 
underscored in "The Surgeon General's Call to Action to Prevent and 
Decrease Overweight and Obesity." This document--published in December 
2001--emphasizes the seriousness of the health problems associated with 
being overweight or obese and outlines strategies that communities can 
use to address overweight and obesity by focusing on both improved 
nutrition and increased physical activity. The document also recommends 
providing more healthful food options on school campuses as well as 
requiring physical education in all school grades. USDA officials 
reported that Team Nutrition and CDC collaborate on an ongoing basis 
and are currently developing implementation materials for schools to 
use to improve their school nutrition environment. The materials 
address issues such as offering and promoting nutritious food and 
beverage options in vending machines, school stores, and a la carte. 
The officials said they will also report on case studies of schools 
that have made successful changes.

Schools Moving Toward Meeting Nutrition Requirements, but Improvements 
Needed:

Schools have made measurable progress, nationwide, in meeting USDA 
nutrition requirements and other guidelines over the past decade. 
Additional improvement, however, is needed not only in meeting the 
nutrition requirements, but also in encouraging students to eat more 
healthfully. With respect to nutritional quality, on average, schools 
are exceeding the requirements for a variety of nutrients. However, 
while most schools have reduced the average percent of calories from 
fat in school lunches, few have met the required goal for fat content. 
Regarding promoting healthy eating, nutrition education is taught at 
most schools, but studies suggest it may not be enough to show an 
impact on student behavior. Moreover, students at most secondary 
schools and many elementary schools nationwide have access to a variety 
of food and beverages from vending machines, school stores, and other 
sources that is of little nutritional value--for example, high in fat, 
sodium, and/or added sugars, but low in nutrients such as vitamins or 
minerals.

School Lunch Nutrition Improving but Still Not Meeting Requirements:

In school year 1991-92, a USDA national study to determine the 
nutritional quality of school meals found that schools were generally 
meeting standards for nutrients, including protein, vitamins A and C, 
calcium, and iron.[Footnote 8] The average calorie content of 
elementary school lunches was somewhat higher than the standard, and 
the calorie content of secondary school lunches was slightly lower than 
the standard. However, the study also found that levels of fat, 
saturated fat, and sodium[Footnote 9] in school lunches were not 
consistent with the standards set out in the "Dietary Guidelines for 
Americans."[Footnote 10] As a result of those findings, USDA developed 
the School Meals Initiative to improve the nutritional quality of 
school meals through, for example, changes in meal menu planning 
requirements and enhanced training and technical assistance for school 
food service personnel.[Footnote 11]

In school year 1998-99, a USDA follow-up study provided an updated 
national picture of the nutrient profile of school meals.[Footnote 12] 
According to this study, schools across the nation have, on average, 
continued to meet or exceed required nutrient standards for protein, 
vitamins A and C, calcium, and iron. The average calorie content of 
elementary school lunches continued to be somewhat higher than the 
standard and that of secondary school lunches, slightly lower. The 
study also reported a significant trend toward lower total fat levels 
in school lunches from nearly 38 percent of total lunch calories in 
1991-92 down to about 34 percent in 1998-99, however, still above the 
required 30-percent standard. Additionally, according to the study, 
while the number of schools meeting the 
30-percent standard had increased substantially, more than three-
quarters of elementary and secondary schools still had not yet achieved 
that goal. Sodium levels had also declined significantly in both 
elementary and secondary schools but were still considerably higher 
than the 800-mg. standard. Table 1 compares the nutritional content 
standards with findings from these two studies.

Table 1: Mean Nutrient and Caloric Content of School Lunches Offered in 
School Year 1998-99 and School Year 1991-92 Compared with NSLP 
Standards:

Elementary schools:

Protein (gm); NSLP standard: 10; SY 1991-92[A,B]: 30; SY 1998-99[A,B]: 
30; Percent change (SY 1991-92 vs. SY 1998-99): 0.

Vitamin A (mcg RE); NSLP standard: 224; SY 1991-92[A,B]: 397; SY 1998-
99[A,B]: 491; Percent change (SY 1991-92 vs. SY 1998-99): +24[D].

Vitamin C (mg); NSLP standard: 15; SY 1991-92[A,B]: 28; SY 1998-
99[A,B]: 37; Percent change (SY 1991-92 vs. SY 1998-99): +32[D].

Calcium (mg); NSLP standard: 286; SY 1991-92[A,B]: 483; SY 1998-
99[A,B]: 505; Percent change (SY 1991-92 vs. SY 1998-99): +5[D].

Iron (mg); NSLP standard: 3.5; SY 1991-92[A,B]: 4.1; SY 1998-99[A,B]: 
4.6; Percent change (SY 1991-92 vs. SY 1998-99): +12[D].

Sodium (mg); NSLP standard: 800; SY 1991-92[A,B]: 1,399; SY 1998-
99[A,B]: 1,285; Percent change (SY 1991-92 vs. SY 1998-99): -8[D].

Cholesterol (mg); NSLP standard: 100; SY 1991-92[A,B]: 84; SY 1998-
99[A,B]: 68; Percent change (SY 1991-92 vs. SY 1998-99): -19[D].

Total calories; NSLP standard: 664; SY 1991-92[A,B]: 715; SY 1998-
99[A,B]: 738; Percent change (SY 1991-92 vs. SY 1998-99): +3.

% Calories from fat; NSLP standard: 30%; SY 1991-92[A,B]: 37.5%; SY 
1998-99[A,B]: 33.5%; Percent change (SY 1991-92 vs. SY 1998-99): -11.

% Calories from saturated fat; NSLP standard: 10%; SY 1991-92[A,B]: 
15.2%; SY 1998-99[A,B]: 11.9%; Percent change (SY 1991-92 vs. SY 1998-
99): -22[D].

Secondary schools:

Protein (gm); NSLP standard: 16; SY 1991-92[A,B]: 33; SY 1998-99[A,B]: 
33; Percent change (SY 1991-92 vs. SY 1998-99): 0.

Vitamin A (mcg RE); NSLP standard: 300; SY 1991-92[A,B]: 418; SY 1998-
99[A,B]: 519; Percent change (SY 1991-92 vs. SY 1998-99): +24[D].

Vitamin C (mg); NSLP standard: 18; SY 1991-92[A,B]: 34; SY 1998-
99[A,B]: 42; Percent change (SY 1991-92 vs. SY 1998-99): +24[D].

Calcium (mg); NSLP standard: 400; SY 1991-92[A,B]: 518; SY 1998-
99[A,B]: 542; Percent change (SY 1991-92 vs. SY 1998-99): +5[D].

Iron (mg); NSLP standard: 4.5; SY 1991-92[A,B]: 4.8; SY 1998-99[A,B]: 
5.0; Percent change (SY 1991-92 vs. SY 1998-99): +4[C].

Sodium (mg); NSLP standard: 800; SY 1991-92[A,B]: 1,641; SY 1998-
99[A,B]: 1,502; Percent change (SY 1991-92 vs. SY 1998-99): -8[D].

Cholesterol (mg); NSLP standard: 100; SY 1991-92[A,B]: 95; SY 1998-
99[A,B]: 75; Percent change (SY 1991-92 vs. SY 1998-99): -21[D].

Total calories; NSLP standard: 825; SY 1991-92[A,B]: 820; SY 1998-
99[A,B]: 798; Percent change (SY 1991-92 vs. SY 1998-99): -3.

% Calories from fat; NSLP standard: 30%; SY 1991-92[A,B]: 37.5%; SY 
1998-99[A,B]: 33.7%; Percent change (SY 1991-92 vs. SY 1998-99): -
10[D].

% Calories from saturated fat; NSLP standard: 10%; SY 1991-92[A,B]: 
14.6%; SY 1998-99[A,B]: 11.8%; Percent change (SY 1991-92 vs. SY 1998-
99): -19[D].

Source: SNDA-II pp. 148-155.

Note: NSLP Standards reflect minimums defined in current program 
regulations for grades K-6 (elementary schools) and grades 7-12 
(secondary schools). NSLP standards for the percentage of calories from 
fat and saturated fat were not in effect during SY 1991-92. NSLP 
standards reflect minimum content requirements for total calories, 
protein, vitamins A and C, calcium, and iron and maximum content 
limitations for sodium, cholesterol, calories from fat, and calories 
from saturated fat.

[A] Data for all public schools in the first School Nutrition Dietary 
Assessment Study (SNDA-I).

[B] Data from the second School Nutrition Dietary Assessment Study 
(SNDA-II).

[C] Difference between SY 1991-92 and SY 1998-99 is statistically 
significant at the 0.01 level.

[D] Difference between SY 1991-92 and SY 1998-99 is statistically 
significant at the 0.001 level.

[End of table]:

The 1998-99 study also points out that schools may also offer low fat 
menu options that allow students to choose menu items that provide a 
lunch that meets the standard, even when the average lunch offered 
exceeds the 
30-percent standard for calories from fat. The percentage of elementary 
schools that provided such low-fat options increased from 34 percent to 
82 percent and for secondary schools, from 71 percent to 91 percent 
between school years 1991-92 and 1998-99. The study further reported 
that 99 percent of elementary schools and 96 percent of secondary 
schools were meeting the cholesterol standard of 100 mg. or less. 
However, only 
1 percent of elementary schools and less than 1 percent of secondary 
schools were meeting the sodium content standard of 800 mg. or less.

Efforts to Encourage Healthy Eating Could be Increased at Many Schools:

In addition to making progress in serving nutritious meals, schools 
have made a variety of efforts to encourage healthy eating among 
students. However, such efforts remain limited in many locations, 
according to national studies. Nutrition education is one way to 
promote good dietary habits among youth, and a Department of Education 
study found that in school year 1996-97, 88 percent of kindergarten 
through fifth-grade teachers presented lessons about 
nutrition.[Footnote 13] According to that study, the average total 
amount of time teachers devoted to nutrition education was 13 hours per 
school year. Further, a CDC study found that most schools, at all grade 
levels, require some nutrition to be taught, however, the median amount 
of time spent on nutrition education as part of schools' health 
education classes was 5 hours during the elementary years, 5 hours 
during the high school years, and 4 hours during the middle school 
years.[Footnote 14] A 1995 report summarizing the research on nutrition 
education for school age children concluded that time and intensity of 
the instruction offered do matter. Programs with longer durations, more 
contact hours, and more components, such as parent involvement and 
changes in school meals, result in more positive outcomes.[Footnote 15] 
Additionally, the study emphasizes the importance of focusing on 
student behavior--an approach also supported by the Department of 
Education report. The study concludes that, given the limited amount of 
time available, those interventions that focus on specific student 
behaviors, such as reduced fat intake or use of salt, result in more 
behavioral change than do general nutrition education programs. 
Finally, the study underscores the importance of providing a healthy 
school environment to reinforce and encourage students to make healthy 
eating choices.

The school environment--both inside and outside the cafeteria--is 
important in encouraging healthy eating by providing students with 
access to healthful food choices and models of healthful food 
practices. The 
2000 CDC study highlights the need to address those aspects of the 
school nutrition environment that are not regulated by USDA, such as a 
la carte cafeteria items and food and beverages in vending machines, 
school stores, and snack bars.[Footnote 16] The study reports that 
while many schools offered low fat foods and fruits and vegetables, 
many also offered foods and beverages of limited nutritional value that 
competed with the healthful food for student selection. For example, 
while 36 percent of elementary school SFAs served low-fat baked goods a 
la carte in the cafeteria, nearly 49 percent served baked goods that 
were not low in fat. Additionally, about 43 percent of elementary 
schools, 74 percent of middle schools, and 98 percent of high schools 
have vending machines, school stores, canteens, or snack bars, 
according to the study, which often offered foods high in fat, sodium, 
or added sugars. Table 2 shows the percentage of schools that offer 
various foods for sale to students in competition with school lunches 
both within the cafeteria as a la carte selections and outside the 
cafeteria.

Table 2: Percentage of Schools Offering Selected Foods in Competition 
with School Lunches:

Numbers in percent.

Type of food or beverage.

Low in fat:

100% fruit or vegetable juice; Schools offering food or beverage a la 
carte: Elementary schools: 57.8; Schools offering food or beverage a la 
carte: Middle/Junior high schools: 63.9; Schools offering food or 
beverage a la carte: Senior high schools: 77.4; [Empty]; Schools where 
students can purchase food or beverage in vending machines, school 
store, canteen, or snack bar: Elementary schools[A]: 49.4; Schools 
where students can purchase food or beverage in vending machines, 
school store, canteen, or snack bar: Middle/Junior high schools[B]: 
53.1; Schools where students can purchase food or beverage in vending 
machines, school store, canteen, or snack bar: Senior high schools[C]: 
65.0.

Fruits or vegetables; Schools offering food or beverage a la carte: 
Elementary schools: 68.1; Schools offering food or beverage a la carte: 
Middle/Junior high schools: 74.0; Schools offering food or beverage a 
la carte: Senior high schools: 90.4; [Empty]; Schools where students 
can purchase food or beverage in vending machines, school store, 
canteen, or snack bar: Elementary schools[A]: 20.0; Schools where 
students can purchase food or beverage in vending machines, school 
store, canteen, or snack bar: Middle/Junior high schools[B]: 11.8; 
Schools where students can purchase food or beverage in vending 
machines, school store, canteen, or snack bar: Senior high schools[C]: 
22.0.

Low-fat cookies, crackers, pastries; Schools offering food or beverage 
a la carte: Elementary schools: 36.1; Schools offering food or beverage 
a la carte: Middle/Junior high schools: 40.8; Schools offering food or 
beverage a la carte: Senior high schools: 48.0; [Empty]; Schools where 
students can purchase food or beverage in vending machines, school 
store, canteen, or snack bar: Elementary schools[A]: 26.4; Schools 
where students can purchase food or beverage in vending machines, 
school store, canteen, or snack bar: Middle/Junior high schools[B]: 
37.7; Schools where students can purchase food or beverage in vending 
machines, school store, canteen, or snack bar: Senior high schools[C]: 
49.6.

Low-fat salty snacks; Schools offering food or beverage a la carte: 
Elementary schools: 29.5; Schools offering food or beverage a la carte: 
Middle/Junior high schools: 42.6; Schools offering food or beverage a 
la carte: Senior high schools: 58.3; [Empty]; Schools where students 
can purchase food or beverage in vending machines, school store, 
canteen, or snack bar: Elementary schools[A]: 44.5; Schools where 
students can purchase food or beverage in vending machines, school 
store, canteen, or snack bar: Middle/Junior high schools[B]: 54.5; 
Schools where students can purchase food or beverage in vending 
machines, school store, canteen, or snack bar: Senior high schools[C]: 
65.0.

High in fat, sodium, or added sugars:

Soft or sports drinks or fruit drinks not 100% juice; Schools offering 
food or beverage a la carte: Elementary schools: 19.0; Schools offering 
food or beverage a la carte: Middle/Junior high schools: 40.3; Schools 
offering food or beverage a la carte: Senior high schools: 57.2; 
Schools offering food or beverage a la carte: Senior high schools: 
77.4: 90.4: 48.0: 58.3: High in fat, sodium, or added sugars: [Empty]; 
High in fat, sodium, or added sugars: 58.1; Schools where students can 
purchase food or beverage in vending machines, school store, canteen, 
or snack bar: Middle/Junior high schools[B]: 83.5; Schools where 
students can purchase food or beverage in vending machines, school 
store, canteen, or snack bar: Senior high schools[C]: 93.6.

Chocolate candy; Schools offering food or beverage a la carte: 
Elementary schools: 2.4; Schools offering food or beverage a la carte: 
Middle/Junior high schools: 8.9; Schools offering food or beverage a la 
carte: Senior high schools: 23.7; Schools offering food or beverage a 
la carte: Senior high schools: 77.4: 90.4: 48.0: 58.3: High in fat, 
sodium, or added sugars: [Empty]; High in fat, sodium, or added sugars: 
29.2; Schools where students can purchase food or beverage in vending 
machines, school store, canteen, or snack bar: Middle/Junior high 
schools[B]: 46.6; Schools where students can purchase food or beverage 
in vending machines, school store, canteen, or snack bar: Senior high 
schools[C]: 72.2.

Cookies, crackers, pastries not low-fat; Schools offering food or 
beverage a la carte: Elementary schools: 48.8; Schools offering food or 
beverage a la carte: Middle/Junior high schools: 66.8; Schools offering 
food or beverage a la carte: Senior high schools: 79.9; Schools 
offering food or beverage a la carte: Senior high schools: 77.4: 90.4: 
48.0: 58.3: High in fat, sodium, or added sugars: [Empty]; High in fat, 
sodium, or added sugars: 52.6; Schools where students can purchase food 
or beverage in vending machines, school store, canteen, or snack bar: 
Middle/Junior high schools[B]: 61.2; Schools where students can 
purchase food or beverage in vending machines, school store, canteen, 
or snack bar: Senior high schools[C]: 80.7.

Salty snacks not low-fat; Schools offering food or beverage a la carte: 
Elementary schools: 25.8; Schools offering food or beverage a la carte: 
Middle/Junior high schools: 40.6; Schools offering food or beverage a 
la carte: Senior high schools: 57.8; Schools offering food or beverage 
a la carte: Senior high schools: 77.4: 90.4: 48.0: 58.3: High in fat, 
sodium, or added sugars: [Empty]; High in fat, sodium, or added sugars: 
51.0; Schools where students can purchase food or beverage in vending 
machines, school store, canteen, or snack bar: Middle/Junior high 
schools[B]: 62.4; Schools where students can purchase food or beverage 
in vending machines, school store, canteen, or snack bar: Senior high 
schools[C]: 83.0.

Source: School Health Policies and Programs Study, 2000.

[A] Among the 43.0 percent of elementary schools with a vending 
machine, school store, canteen, or snack bar.

[B] Among the 73.9 percent of middle/junior high schools with a vending 
machine, school store, canteen, or snack bar.

[C] Among the 98.2 percent of high schools with a vending machine, 
school store, canteen, or snack bar.

[End of table]:

According to the study, a relatively small percentage of school 
districts have policies in place that require the sale of healthy 
choices or that restrict the sale of foods with little nutritional 
value. For example, only about 19 percent of districts require schools 
to offer fruit and vegetables as a la carte items, and 23 percent of 
districts require schools to prohibit the sale of foods that have 
little nutritional value as a la carte items. Furthermore, about half 
of school districts have a contract that gives a company rights to sell 
soft drinks at schools in the district. Most of those districts receive 
a percentage of sales receipts or other incentives.[Footnote 17] 
Finally, in most schools, organizations such as student clubs, sports 
teams, and parent-teacher associations sell food to raise money, and 
the food sold is typically high in fat and added sugars, according to 
the study.

Barriers Exist to Providing Nutritious Food and Encouraging Healthy 
Eating Choices:

School and SFA officials in the 22 schools in 13 school districts that 
we visited cited a number of barriers to meeting nutrition requirements 
and improving school lunch nutritional quality. However, many officials 
we spoke with were more concerned with the barriers they faced in 
encouraging healthy eating among students and establishing a broader 
community approach. Regarding improving nutritional quality and meeting 
USDA requirements, SFA officials said that the pressure to balance 
their budgets could affect the food served in the school.[Footnote 18] 
Also, according to state officials we spoke with, they have limited 
ability to enforce the nutrition requirements. Regarding encouraging 
healthy eating, school officials said that they have limited time and 
resources available to teach nutrition education. Additionally, school 
principals and organizations are reluctant to limit the sale of food 
and beverages of limited nutritional value at the schools that we 
visited because they use the money to support student activities not 
covered in the school budget.

Budget Pressures Can Affect Nutritional Quality of Food:

SFA officials we talked with cited financial barriers to providing 
nutritious meals. Many officials said that they are under pressure to 
balance their budgets, while at the same time provide meals that meet 
USDA nutrition guidelines and appeal to students. Some officials said 
that providing a lunch that meets USDA's guidelines for nutrition and 
comes in under budget is achievable, but the challenge is in preparing 
healthful foods that are also appealing to the students and that 
students will select and eat. Many SFA officials said that when they 
make changes in the menu items offered, such as lowering the fat 
content or introducing new items, they run the risk that students will 
not like the changes and will decline to participate. They noted that 
because food service programs are typically required to operate on a 
break-even basis, and student meal payments make up a large part of 
their revenue, a decline in participation could have a negative effect 
on the budget. For example, in Rhode Island, an official told us that 
several years ago SFA officials decided to no longer offer deep-fried 
French fries to the students. Disappointed by this decision, the 
students boycotted the entire school lunch program. Within a week the 
school restored them to the menu--but as an a la carte item. Some SFA 
officials mentioned that the school food service staff has sometimes 
been reluctant to adopt standardized recipes that did not include bacon 
fat, butter, cream, or other ingredients that made their recipes 
popular with the students.

When schools serve meals that do not comply with federal nutrition 
requirements, enforcement options are limited, according to state and 
federal officials. If the state School Meals Initiative review reveals 
noncompliance, the state agency works with district officials to 
develop a plan to correct deficiencies and follows up to monitor the 
progress of the plan. Although regulations allow for withholding of 
federal meal reimbursements if the SFA has not been acting in good 
faith to meet the terms of the corrective action plan, state and USDA 
officials questioned whether this offers a practical or realistic 
solution because of the possibility of program cutbacks or closure and 
the effect on the students, especially those receiving free or reduced 
price lunches.

Efforts to meet various school and district financial pressures have 
led SFAs to serve less healthful a la carte items in the cafeteria in 
competition with school lunches. While a la carte items can include 
such things as fruit and milk, they may also include cookies, candy, 
ice cream, and deep-fried French fries. One SFA director said that a la 
carte sales help her balance the budget. She said the SFA probably 
sells about $600 a day in a la carte items, such as pudding, toaster 
pastry, beef jerky, and cheese sticks. Less healthful a la carte items 
may be sending a mixed nutrition message to students, according to 
officials. SFA officials said that they recognize that some of the a la 
carte items offered are less nutritious or healthful, but said they 
need the revenue the items generated to help balance their budgets.

Competing Time and Budget Pressures May Compromise Healthy Eating 
Environment in Schools:

School and SFA officials we spoke with said that time constraints and 
financial needs within the school sometimes compromise efforts to 
encourage healthy eating choices among students. Principals, teachers, 
and other officials said that classroom time is focused almost entirely 
on making sure that students meet state academic standards, and little 
time is left to include subjects or information not included on the 
state academic standards test.[Footnote 19] One SFA director said that 
state testing is leading the curriculum--social skills, nutrition 
education, and other subjects are being left out. As another official 
said, "If you want it taught, get it on the test." Three states we 
visited required students to take nutrition education as part of a 
health class at the secondary level, but only one state included it 
when preparing for a required statewide health test. Several schools we 
visited taught some nutrition education--often as part of a consumer 
and family sciences course, health, or physical education at the 
secondary level (middle, junior, and senior high schools). These 
classes were usually elective and taken by only a few students. Some 
districts we visited included nutrition as part of their health 
curriculum at various grade levels, but typically limited it to a few 
hours class time. Finally, while a variety of materials and information 
is available to assist teachers in presenting nutrition information to 
both elementary and secondary students, some teachers said they were 
not aware of, or did not have time to locate and utilize these 
resources.

Students at the schools we visited also had access to soft drinks, 
candy, and other foods of limited nutritional value elsewhere in the 
school because, according to officials, the school relies on the 
revenue. For example, at several schools we visited the profits from 
soda vending machines generated several thousand dollars over a year's 
time to be used at the discretion of the principal. Some principals 
said that it was their only funding source for expenditures such as 
awards for students' academic and athletic achievements, for school or 
class fieldtrips, and for other educational opportunities. One 
principal bought a bassoon for the school orchestra because a 
particularly promising low-income student musician needed it. Officials 
said that finding another source of funding to replace that generated 
by these machines would be difficult, and as one principal said, "It 
would be World War III if the machines were removed.":

Many schools that we visited also sold food and beverages as part of 
Parent Teacher Association or athletic team fundraisers or other school 
club sales. They acknowledged that often these items sold outside of 
the cafeteria--such as candy and cookies--are of limited nutritional 
value. However, officials said that the profits made from these sales 
provide funds for school activities or projects that would otherwise 
not be funded, so officials say they are reluctant to restrict or 
prohibit them. Additionally, in some schools that we visited, a healthy 
nutrition environment was compromised by teachers and others using 
foods of limited nutritional value, such as candy and cookies, as a 
reward for good classroom or hallway behavior, scoring well on a test 
or project, or from even bus drivers for good conduct on the bus. Some 
school or PTA activities also included refreshments that were of 
limited nutritional value. Officials said that foods of limited 
nutritional value were often less expensive and more convenient.

Schools Have Implemented Approaches to Overcome Barriers:

The schools and SFAs that we visited had established a variety of 
approaches to overcome the barriers they face in providing nutritious 
food and encouraging students to make healthy eating choices. Nearly 
all the visited schools had taken actions to improve the nutritional 
quality of the food served to students and at the same time help ensure 
that the food would be appealing to the students. To promote healthy 
eating habits among their students, some schools offered nutrition 
education both in and outside the classroom. Some had taken steps to 
limit students' access to foods of limited nutritional value at school. 
A number of schools had enlisted community organizations and businesses 
for assistance and resources to help sponsor activities outside the 
classroom such as health fairs, family events, and nutrition awareness 
campaigns. Additionally, state and federal agencies had a number of 
efforts in place to support local initiatives and community-wide 
collaborations.

A Variety of Efforts Are in Place to Improve Nutritional Quality of 
School Meals:

In most of the SFAs that we visited, officials had taken a number of 
steps to improve the nutritional quality of the food. For example, some 
food service officials had modified the recipes of several foods that 
are popular with students, such as enchiladas and macaroni and cheese, 
to make them more nutritious yet still appealing to student palates. 
Their techniques included baking rather than frying, reducing salt 
usage, and substituting low-fat ingredients wherever possible, such as 
in gravies, cheese sauces, and salad dressings. At one high school in 
Kentucky, the food service replaced the nacho cheese sauce with a low-
fat substitute, and students told us they were not aware of the change. 
Several SFA directors said that they worked with vendors of prepared 
food to provide items that had healthier nutritional specifications and 
lower fat content. For example, an SFA in Washington State negotiated 
with a vendor to supply French fries with less fat and sodium. In 
Kentucky, an SFA worked with venders to provide low-fat pizza and 
chicken nuggets.

School food service managers and school officials found that expanding 
the number and variety of healthy food choices increased the likelihood 
that students would select them. Two of the schools that we visited 
were part of a six-school research project that focused on increasing 
the number of healthy lunch options available to students. Researchers 
reported that when the number of healthy entrees was increased, the 
percent of students purchasing them increased and has stayed higher 
than pre-intervention levels. Also, several SFAs periodically provided 
free taste testing or samples of proposed new additions to the school 
lunch. SFA directors considered the student preferences and made 
changes in the menu as long as their food service operation broke even 
financially as required. We visited an elementary school in northern 
Virginia when students were participating in a taste test. The students 
said that they enjoyed the opportunity to taste the new items. Students 
filled out an evaluation form, after they ate each sample, providing 
comments and indicating how much they liked or disliked the item. The 
SFA director said that the tastings increased student awareness of 
healthier food items and induced them to taste items that they may not 
have normally chosen on their own.

Schools Have Implemented Activities to Promote Healthy Eating Choices:

The schools and SFAs we visited had efforts in place to overcome the 
barriers to encouraging healthy eating. They initiated changes in the 
cafeteria and education activities in the classroom and beyond. Some 
actions extended throughout the school and to the local community. 
Efforts to support school activities are also taking place at the state 
and federal levels.

Efforts in the Cafeteria:

SFAs in the districts that we visited had introduced a variety of 
approaches in their cafeterias to make healthier school food more 
appealing to students. One approach was to package the food in a manner 
similar to what students find in fast-food restaurants. For example, a 
high school in Washington State modeled its salads on those found in a 
leading chain restaurant. A Kentucky high school served its reduced-fat 
pizzas in small boxes imprinted with a brand name logo; and a Rhode 
Island high school used colorful wrappers for its sandwiches. In 
another approach, a California SFA found that vegetable consumption 
increased when kitchen staff let the students serve themselves from the 
garden bar rather than take vegetables served in individual 
bowls.[Footnote 20] In addition, one district we contacted increased 
the appeal of healthier food by reducing the selling price of items 
such as string cheese, fresh fruit, and sunflower seeds.

Some schools and SFAs we visited had taken actions to make their 
cafeterias more attractive to students. In several districts, schools 
tried to recreate, to some degree, the experience students find in 
popular restaurants and food courts. They configured school cafeterias 
with multiple serving lines, each with a different theme. For example, 
at a high school in Kentucky, one line served the standard school lunch 
entrees, while other lines were for salads and submarine sandwiches. A 
high school in Michigan added an area that sold just soup, salad, and 
deli-sandwiches. Several schools made cafeterias more inviting places 
to eat by incorporating colorful décor. For example, the cafeteria 
manager at a Texas high school installed red and white awnings above 
the doorways into the food area to make it look more like a café. One 
SFA in Rhode Island had decorated school cafeterias with specific 
themes. For example one junior high school cafeteria had a nautical 
décor, and a high school cafeteria had murals of maps and flags 
representing each of the countries of origin represented in the student 
body.

In several districts, SFAs used the monthly school menu to reach out 
beyond the cafeteria and focus attention on nutrition. Some menus 
contained items of nutritional interest or facts such as the calories 
and fat content in the various school foods. School food service 
managers said that since the students often took the menus home, it 
helped them reach parents and guardians with their message of healthy 
eating choices. In a related example, a Texas school district reported 
putting a new nutrition article on their website every month.

Educational Efforts:

Many schools had identified opportunities to instruct students about 
nutrition both in the classroom and in other school activities. One SFA 
in California had a nutritionist visit fourth grade classrooms to 
explain the food pyramid and the importance of fruits and vegetables in 
their diet. As part of her presentation, she gave the students samples 
of different fruits. At a Rhode Island middle school, we watched a 
family and consumer science class prepare a raspberry ice yogurt as a 
healthful alternative to the traditional milk shake. The teacher said 
she used USDA nutrition education materials as well as those from food 
industry associations. She also had class visits to farms, a farmers' 
market, and restaurant kitchens. An SFA in California reported a 
noticeable change in what students chose and ate after providing 
students with more information about fruits and vegetables. Its schools 
placed nutrition-themed posters in hallways and the cafeterias and 
started teaching nutrition in the classroom. With the help of a Team 
Nutrition grant, a Michigan elementary school integrated nutrition 
education into existing reading and math curriculum. The project helped 
the school overcome the difficulty of finding time to teach nutrition, 
a subject with less priority to teachers because it is not included in 
state academic standards assessments. The school was also using the 
School Health Index for Physical Activity and Healthy Eating, a self-
assessment and planning guide developed by CDC, to assess its nutrition 
and physical activity policies and create a healthy school environment.

School Policies, Practices, and Community Activities:

Some schools and districts had adopted new policies or practices to 
restrict or replace food of limited nutritional value sold in schools. 
These policies and practices varied widely in their scope from those 
limited to a single classroom to school and districtwide efforts. For 
example, at the classroom level, in several elementary schools we 
visited, teachers said that they no longer used candy as a reward in 
the classroom as a means of supporting the healthy eating message. 
Instead, they substituted healthful snacks, stickers, or extra minutes 
for recess as incentives. One teacher in a Rhode Island elementary 
school rewarded her students with pennies for demonstrating good health 
habits. Students could later exchange the pennies for healthful snacks.

At the school level, some schools that sold competitive foods through 
vending machines or in a cafeteria a la carte line, regulated the type 
of items that could be sold. For example, at one Rhode Island 
elementary school, at the principal's request, the food service manager 
replaced school snack bar items, such as candy bars and potato chips, 
with healthier choices, such as rice cereal cookies and raisins. 
According to the food service manager, students accepted the new 
selections with minimal controversy, sales rebounded, and other 
elementary schools in the district adopted the same changes. A Texas 
school district had a similar experience when it revised its vending 
machine policy to include only healthier items. An elementary school 
principal in California said her school made more money selling 
healthier snacks than the limited nutritional value items previously 
sold in the school. One district that we visited in Michigan allows 
middle school students to make snack purchases only after they have 
eaten their regular lunch.

At the district level, one large urban SFA that we visited was 
beginning to implement a broad districtwide food policy that set 
multiple goals focusing on improving the nutritional quality of school 
food, serving enjoyable foods from diverse cultures, and improving the 
quality of food service jobs. The policy also established a Nutrition 
Advisory Board that includes teachers, principals, students, parents, 
and community representatives in addition to district administration 
and SFA staff. Several districts that we visited had established 
policies that prohibited candy and soft drink machines at elementary 
schools and some regulated a la carte sales in their secondary schools. 
A number of districts focused on increasing the offerings of healthier 
items such as milk, water, and juices.

In addition to efforts in the cafeteria, educational efforts, and 
changes in policies and practices to encourage healthy eating, several 
schools that we visited had taken steps to establish a broader more 
systematic healthy school environment that includes both healthy eating 
and physical activity. Two elementary schools in Texas--as part of a 
university and state health department study funded by CDC--were 
working closely with their SFAs to increase low-fat choices in the 
cafeteria, were providing more nutrition education to students, and 
were increasing students' physical activity through physical education 
and other activities. These schools had established a school committee 
of faculty, staff, students, and parents to plan many of the school 
activities. Also, one elementary school that we visited in Rhode Island 
had established a comprehensive school health initiative that included 
both nutrition and physical activity efforts. The school nurse taught 
health and was working on integrating nutrition education into 
classroom lessons. She recently taught a lesson on comparing the 
nutritional information on cereal boxes. The school had established a 
healthy schools committee which meets twice a month and was using a 
$1,000 grant to set up a walking program. Last year, the school held a 
heart health fair for students and parents that included healthful 
snacks and group exercise.

Several school districts had expanded their nutrition education efforts 
beyond the school by collaborating not only with families, but also 
with community organizations and businesses to raise healthy nutrition 
and lifestyle awareness. Several districts held health fairs for 
families of students in which nutrition was a central theme. For 
example, a fair at one Rhode Island school had restaurant chefs speak 
to parents, demonstrate healthful food preparation, and provide samples 
of healthful snacks. Three schools in another Rhode Island district 
also had a health fair that had the sponsorship of organizations such 
as the local police department. A health insurance company sponsored a 
pilot project at two middle schools in Grand Rapids, Michigan, in the 
spring of 2001. The "Trek Around the World" encouraged students to 
increase their physical activity and eat more fresh fruits and 
vegetables.

Many SFA officials, principals, and other officials that we contacted 
said leadership makes a difference in the success of nutrition and 
healthy eating efforts. They emphasized the importance of local 
leadership in implementing and sustaining a successful child nutrition 
and health program in the school and community. For example, one 
elementary school principal made a point of frequently eating fresh 
fruit in front of her students. A middle school administrator roamed 
the cafeteria at lunchtime encouraging students to eat healthful foods. 
In some schools we visited, other people such as a teacher, a physical 
education teacher, the school nurse, or the local parent-teacher 
association president had taken a leadership role in implementing and 
sustaining efforts to encourage good nutrition and create a healthy 
school environment.

State Efforts to Support School Activities:

State efforts to support local leaders in improving school meal 
nutrition and encouraging healthy eating among students in the states 
we visited included a variety of approaches. For example, in Rhode 
Island, a private nonprofit organization facilitated Team Nutrition 
efforts, providing a focal point for assistance and outreach to schools 
and districts. In Michigan, the Michigan State University Extension and 
the Michigan Department of Education worked as a team to promote Team 
Nutrition. The extension service provided materials, information, and 
assistance to schools and SFAs. The state department of education and 
the extension service have a history of collaboration to address a 
variety of state issues, according to state officials. In Kentucky, 
Rhode Island, and Texas, state departments of education and health have 
also established ways to collaborate to address student health issues, 
including nutrition. In California, the state passed legislation that 
will take effect in 2004 that establishes restrictions on beverages 
sold in elementary and middle schools and places nutritional standards 
on the type of foods that can be sold--including in vending machines. 
State education department officials in California report that they are 
working with school districts to promote districtwide healthful food 
policies. School and SFA officials acknowledged that state assistance 
and leadership was valuable in implementing local activities. However, 
USDA officials report that not all states have established a state 
focal point for leadership or have begun collaboration among state 
agencies to address nutrition education.

Federal Efforts to Support School Activities:

A growing support structure for these local efforts is in place at the 
federal level. According to USDA officials, the agency will continue 
and expand its nutrition and healthy eating efforts through the Team 
Nutrition initiative. According to officials from USDA and CDC, they 
collaborate on a number of health efforts to avoid duplication and 
ensure a single message is communicated. Additionally, USDA, CDC, and 
the Department of Education partnered with a number of national 
organizations to sponsor a Healthy Schools Summit in October 2002. The 
conference emphasized collaboration to foster change at the state, 
district, and local levels and launched the establishment of Action for 
Healthy Kids teams in 50 states and the District of Columbia. Further, 
in June 2002, the Secretaries of the Departments of Agriculture, Health 
and Human Services, and Education signed a memorandum of understanding 
to strengthen and promote the education and health of school-age 
children. The memorandum specifies the types of activities the 
departments will conduct over 5 years. For example, USDA will develop 
and distribute grade-specific materials to schools to use in the 
classroom, and Health and Human Services will provide technical 
assistance to help state education agencies support schools in 
selecting or developing effective physical education and nutrition 
education curricula. Additionally, the Department of Education will 
encourage schools to participate in Team Nutrition and encourage state 
boards of education to develop policies that will provide healthy 
school environments. However, the memorandum does not identify specific 
strategies to address how schools will find time to use the materials 
and technical assistance provided by federal agencies given the time 
requirements for meeting state academic standards--for example, by 
facilitating the integration of nutrition education into the existing 
curricula and activities and by focusing on student behavior. 
Furthermore, the memorandum does not specifically address the 
importance of leadership and agency collaborations at the state level 
in addressing nutrition and healthy eating in schools.

Conclusions:

With an urgent health problem threatening the well being of the 
country's youth, it is important that actions be taken to reverse 
current trends toward obesity and related physical problems. While 
schools and the school lunch program cannot be expected to solve these 
problems alone, they are well positioned to positively influence what 
children eat and what they know about the importance of good nutrition. 
However, many schools are sending a mixed message when they provide 
nutritious meals and encourage healthy choices, but at the same time 
rely on the sales of foods of limited nutritious value to fund school 
and student activities. Despite the difficulties of making significant 
changes in the foods sold at schools, a number of schools and districts 
have shown that healthful food policies and practices can be put in 
place. These policies not only help ensure that the food children eat 
at school is healthful; they also provide a positive model within the 
school and an opportunity to learn about healthy eating outside the 
classroom. Many schools, however, continue to face challenges to 
providing nutrition education in the classroom, in part, because of the 
need to focus on subject matter covered to meet state academic 
standards.

Federal efforts to promote and support local initiatives, including 
increasing collaboration among agencies, show promise. The recent 
memorandum of understanding signed by USDA, the Department of Health 
and Human Services, and the Department of Education underscores the 
importance of agencies working together and contributing what they do 
best. This federal partnership could be fruitful in increasing the 
emphasis on, and resources available for, encouraging healthy eating 
and the integration of nutrition education into schools' existing 
curriculum in ways that would meet state academic standards 
requirements while advancing students' awareness of the importance of 
healthy eating.

The state role in promoting nutrition education--both in the classroom 
and beyond--is also seen as an important part of the nutrition and 
healthy eating equation. Efforts in some states are promising. However, 
not all states appear to have established the focused and coordinated 
effort among appropriate state agencies that could facilitate active 
partnering with the federal agencies that provide resources and 
assistance.

Providing healthful food and encouraging healthy eating among students 
is a complex undertaking and schools differ in their needs and 
capabilities so that no single program can be appropriate for all. 
Moreover, healthy eating is only one of the changes needed to address 
the growing overweight and health problems among our nation's youth. 
Ultimately, a more comprehensive program that addresses students' 
entire environment, and one that provides multiple exposures to 
nutritious food and information on healthy eating--as well as promoting 
appropriate physical activity--appears to offer the most hope of 
success. The Surgeon General's office has emphasized the importance of 
individuals and groups, across all settings, working in concert to 
educate people about health issues related to overweight and obesity 
and to promote balancing healthy eating with regular physical activity. 
A number of models have already been developed for schools to use in 
that endeavor, including USDA's Changing the Scene and East Smart-Play 
Hard and CDC's School Health Index. However, nationwide progress could 
be facilitated by enhanced and continuing collaboration among officials 
and organizations at the federal, state, and local level to inform, 
promote, and help sustain efforts.

Recommendations for Executive Action:

We recommend that the Secretaries of Agriculture, Health and Human 
Services, and Education use their recently signed memorandum of 
understanding as a vehicle to:

* identify specific strategies and develop materials to help schools 
promote nutrition education while still meeting the requirements of 
state academic standards and:

* encourage states to identify a focal point in each state to promote 
collaborative efforts that would further develop nutrition education 
activities for the schools.

Agency Comments:

We requested comments on a draft of this report from the Secretary of 
Agriculture or her designee. On April 11, 2003, officials from USDA's 
Food and Nutrition Service, Child Nutrition Division, provided us with 
the following oral comments on the draft. The officials said that they 
were in general agreement with the findings and recommendations as 
presented in the report. However, they said that targeted nutrition 
education training funds, which were provided to states in the past, 
are no longer available, and they believe that, without additional 
funding, states are unlikely to implement our recommendation that each 
state identify a focal point to promote collaborative efforts to 
develop nutrition education activities for schools. We recognize that 
states are currently facing budget shortfalls and may find it difficult 
to create new staff positions at this time. However, we believe that 
states, at a minimum, can identify a focal point from among existing 
positions to promote a focused and coordinated effort among appropriate 
state agencies.

The officials also noted that they believe their major school nutrition 
initiatives--which are Team Nutrition, Changing the Scene, and Eat 
Smart-Play Hard--all play an important role in encouraging schools to 
serve nutritious food and in encouraging children to eat well. We agree 
that such initiatives can play an important role in improving the 
school nutrition environment in schools where they are implemented; 
however, not all schools participate in the initiatives. Our 
recommendations focus on the need for various federal and state 
agencies to work together as a next step to help focus resources and 
activities on nutrition education and other efforts to encourage 
children to eat healthy foods. Regarding this need for collaboration, 
Food and Nutrition Service officials said that they would like to be 
more active in their support for, and collaboration with, CDC. However, 
they believe USDA is not always in a position to support CDC as much as 
they would like and would need additional resources to do so. In our 
review, we did not analyze funding levels of the different agencies. 
Finally, in addition to these observations, USDA provided technical 
comments that we have incorporated as appropriate.

The Department of Health and Human Services provided written comments 
on a draft of this report. (See app. I.) Health and Human Services 
generally agreed with our findings and recommendations and provided 
information on the Steps to a Healthier US initiative. It also provided 
technical comments that we have incorporated as appropriate. Along with 
the technical comments, the department provided a table summarizing the 
strategies for improving school nutrition that were presented in the 
report. We have included the table in appendix I.

The Department of Education also provided written comments on a draft 
of this report. (See app. II.) Education said that the report provides 
a review of the many issues facing schools in their efforts to meet 
USDA nutrition requirements and promote healthy eating among students 
and they also provided additional information on department initiatives 
that support student health and nutrition. However, Education expressed 
concern that the information we present appears to imply that 
accountability provisions in the No Child Left Behind Act may 
contribute to compromising a healthy eating environment in schools, and 
it raised questions about the support for our finding that school 
officials have difficulty finding the time to incorporate nutrition 
education into every day lessons because of pressures to meet state 
academic standards. Our findings are based on the views expressed by 
school and SFA officials we interviewed, and we believe we have fairly 
reflected the views of those officials. We believe that nutrition 
education and other components of a healthy eating environment can and 
should be compatible with, and complementary to, schools' efforts to 
meet the requirements of state academic standards. It is for this 
reason that we have recommended that federal agencies partner and work 
with states to help schools find ways to promote nutrition education 
and healthy eating among students.

Education suggested that we acknowledge other provisions of the No 
Child Left Behind Act that can support nutrition and also suggested 
that we include more examples of physical activity programs in our 
report. It specifically noted the Carol M. White program, which 
includes elements that address both physical activity and healthy 
eating. We recognize that there may be a number of programs that have 
the potential to contribute to nutrition and healthy eating efforts, 
and we agree that physical activity programs could be an important 
component of a healthy school environment. However, the scope of our 
study did not include a comprehensive review of initiatives that 
support nutrition or physical activity. Also, the department 
recommended that we include the Action For Healthy Kids Initiative with 
our examples of community collaborations to promote children's 
nutrition as well as physical activity. We have done so.

Education also provided us with technical comments, which we have 
incorporated as appropriate.

We will send copies of this report to the Secretaries of Agriculture, 
Health and Human Services, and Education, appropriate congressional 
committees, and other interested parties. In addition, the report will 
be available at no charge on GAO's Web site at http://www.gao.gov.

If you or your staff have any questions or wish to discuss this 
material, please call me at (415) 904-2272 or Kay E. Brown at (202) 
512-3674.

David D. Bellis
Director, Education, Workforce, and Income Security Issues:

Signed by David D. Bellis:

[End of section]

Appendix I: Comments from the Department of Health and Human Services:

DEPARTMENT OF HEALTH & HUMAN SERVICES	Office of Inspector General:

APR 15 2003:

Washington, D.C. 20201:

Mr. David D. Bellis:

Acting Director, Education, Workforce and Income Security Issues:

United States General Accounting Office Washington, D.C. 20548:

Dear Mr. Bellis:

Enclosed are the department's comments on your draft report entitled, 
"School Lunch Program: Efforts Needed to Improve Nutrition and 
Encourage Healthy Eating." The comments represent the tentative 
position of the department and are subject to reevaluation when the 
final version of this report is received.

The department provided several technical comments directly to your 
staff.

The department appreciates the opportunity to comment on this draft 
report before its publication.

Dennis J. Duquette:

Signed by Dennis J. Duquette:

Acting Principal Deputy Inspector General:

Enclosure:

The Office of Inspector General (OIG) is transmitting the department's 
response to this draft report in our capacity as the department's 
designated focal point and coordinator for General Accounting Office 
reports. The OIG has not conducted an independent assessment of these 
comments and therefore expresses no opinion on them.

Comments of the Department of Health and Human Services on the General 
Accounting Office's Draft Report, "School Lunch Program: Efforts Needed 
to Improve Nutrition and Encourage Healthy Eating" (GAO-03-506):

General Comments:

The Department of Health and Human Services (department) appreciates 
the opportunity to review and comment on the draft report of the 
General Accounting Office (GAO) entitled School Lunch Program: Efforts 
Needed to Improve Nutrition and Encourage Healthy Eating. The 
department commends GAO for this report which focuses on concerns 
regarding recent trends in children's health and eating habits. 
Obesity, physical activity, and diabetes are among the department's 
priorities.

In fact, the department has many programs underway to help foster a 
healthful school nutrition environment. The recent memorandum of 
understanding between the department and the U.S. Departments of 
Agriculture and Education, "Healthier Children and Youths," will afford 
many opportunities to coordinate efforts to promote healthy eating and 
physical activity behaviors among the nation's school-aged children and 
youths. Together, the departments are actively promoting awareness 
among school officials of the importance of a school environment which 
supports physical activity and eating a nutritious diet so that 
children and youth may stay healthy and be ready to learn.

In addition, Health and Human Services Secretary Tommy Thompson's Steps 
to a HealthierUS (Steps) initiative will advance President George W. 
Bush's HealthierUS goal of helping Americans of all ages to live 
longer, better, and healthier lives. This initiative specifically 
targets diabetes, obesity, asthma, cancer, cardiovascular disease as 
well as risk factors such as poor nutrition and physical inactivity, 
tobacco use, and youth risk behaviors. Building on a growing body of 
prevention research which shows that small, simple steps can often 
prevent or control these health burdens, Steps will promote programs to 
motivate and support responsible health choices, support community 
initiatives to promote and enable healthy choices, encourage healthcare 
and insurance systems which target reduction of risk factors and 
complications of chronic disease, and encourage cooperation among 
policy makers to invest in health promotion.

Also included in our technical comments is a draft table which provides 
a clear summary of ideas that can be used to improve school nutrition. 
This draft table would serve as a complement to the narrative.

Recommendations for Executive Action:

"We recommend that the Secretaries of Agriculture, Health and Human 
Services, and Education use their recently signed memorandum of 
understanding as a vehicle to
identify specific strategies and develop materials to help schools 
promote nutrition education while still meeting the demands of state 
standards based assessments, and:

* direct states to identify a focal point in each state to promote 
collaborative efforts that would further develop nutrition education 
activities for the schools.":

Department Response:

In the second bullet, the department would like the word "direct" 
changed to the word "encourage." To "direct states to identify a focal 
point in each state..." may be perceived by some as an unfunded federal 
mandate. Under the terms of the current memorandum of understanding, as 
stated in the report, the department will provide technical assistance 
to state education agencies to help schools select or develop effective 
physical education and nutrition education curricula.

Strategies for Improving School Nutrition:

[See PDF for image]

[End of table]

[End of section]

Appendix II: Comments from the Department of Education:

UNITED STATES DEPARTMENT OF EDUCATION:

THE UNDER SECRETARY:

April 15, 2003:

Mr. David D. Bellis Acting Director Education, Workforce, and Income 
Security Issues General Accounting Office:

Washington, DC 20548:

Dear Mr. Bellis:

Thank you for the opportunity to review and comment on the draft 
report, "School Lunch Program: Efforts Needed to Improve Nutrition and 
Encourage Healthy Eating." The report provides a review of the many 
issues facing schools in their efforts to meet USDA nutrition 
requirements and promote healthy eating among students. We were 
particularly pleased to see the auditors' review of some of the 
challenges that schools face trying to serve nutritious foods and teach 
students to eat healthy foods, as well as the creative methods some 
schools are using to overcome those challenges. We have a number of 
comments and suggestions below for improving the report and making it 
more accurate and complete. We also have enclosed some more specific 
and technical comments.

We strongly recommend the deletion of the unsupported statement on 
pages 15 and 16 (and especially footnote 17) that appears to imply that 
the accountability provisions in the No Child Left Behind Act (NCLB) 
may contribute to "compromising" a healthy eating environment in the 
schools. On the contrary, as noted below, NCLB has many provisions that 
promote a safe and healthy environment for students, conducive to 
learning. Furthermore, the accountability provisions are designed to 
support learning and parental choice and should in no way compromise a 
healthy eating environment in the schools. While we have no problems 
with the recommendation on helping school districts identify strategies 
and develop materials to help schools promote nutrition education while 
still meeting the demands of state academic standards, we also have 
some concerns about related statements on pages 5, 23, 24, and 25 on 
related issues. In the enclosure, we suggest some revisions that make 
these statements more appropriate.

On pages 21 and 22, the auditors include examples of nutrition and 
physical activity collaborations with community organizations. The 
Action for Healthy Kids (AFHK) Initiative, which came out of the 
Healthy Schools Summit held last fall in Washington, D.C., has state 
nutrition and physical activity teams that are examples of the state 
collaborations the report recommends. Some of these state teams are 
working directly with schools in their areas on nutrition and physical 
activity issues. Alicia Moag-Stahlberg, M.S., R.D., L.D., is the 
Executive Director, and the organization's Internet address is 
www.ActionForHealthyKids.org.	All five of the states your auditors 
visited 
for this report have AFHK state teams. We recommend that you expand 
your examples of community organization collaborations to include the 
AFHK state teams.

On page 23 of the report, the auditors discuss Federal efforts to 
support school activities in health and nutrition. It would be helpful 
if the report also acknowledged the provisions in NCLB that can be used 
to support nutrition, physical education, and health-related services. 
For example, provisions in Title I (section 1115(e)(2)) and the Carol 
M. White Physical Education program under Title V (Part D, Subpart 10) 
of the Elementary and Secondary Education Act (ESEA), as amended by 
NCLB (a competition for new awards was announced on April 1, 2003) 
should be mentioned as supportive of improved nutrition and health. 
Additionally, Title V of ESEA could support nutrition education and 
other related program activities, and some funds from after-school 
programs under the 21st Century Community Learning Centers can be used 
for nutrition activities (including after-school snacks to provide 
nourishment so that students can participate well in learning 
activities).

Additionally, the President has requested $10 million in fiscal year 
2004 for a new physical education initiative that would help build 
capacity nationally for long-term improvements in physical education. 
Grants to school districts would support the demonstration of high-
quality, research-based approaches for incorporating regular physical 
activity into students' everyday lives and promoting lifelong personal 
fitness activities and healthy habits tied to state standards in 
physical education. Each grant would include a rigorous evaluation 
component designed to assess outcomes, including student success in 
increasing knowledge of, and forming positive attitudes about, physical 
fitness, as well as attaining increased levels of fitness. Results of 
this demonstration activity would be widely disseminated to state and 
local educational agencies and community-based organizations that work 
with youth. We hope that this initiative will be included in your 
revised discussion of physical activity programs.

Although the report does include some examples of physical activity 
programs, we hope this discussion will be expanded as noted above. In 
addition to the health and wellness benefits of physical activity, 
preliminary research indicates a direct link between physical activity 
and improved academic performance. Studies have found that 
participation in physical activity increases adolescents' self-esteem, 
as well as physical and mental health. Physically active students are 
also less likely to be regular or heavy smokers and to use drugs or 
alcohol; they are more likely to stay in school and have good conduct 
and high academic achievement.

In addition to our interest in the link between nutrition and physical 
activity programs, we are also interested in the research done with 
students in each of the states that GAO visited. The draft report 
includes very few examples of student comments or feedback, especially 
about the success stories from individual states. Therefore, we 
recommend that you revise your discussion to incorporate more of this 
valuable student information.

We appreciate the mention of the memorandum of understanding (MOU) 
among the Departments of Agriculture, Health and Human Services, and 
Education. Since the
creation of this MOU, we have worked aggressively to fulfill our 
responsibilities to promote healthy eating and physical activity. We 
have coordinated with USDA and HHS to develop a better understanding of 
the health-related programs of each department.

Again, thank you for providing a copy of this draft report for our 
review.	The Department of Education has an important interest in 
ensuring that children are healthy and ready to learn. We appreciate 
the opportunity to comment and would be glad to assist in the 
redrafting or reviewing of a revised draft response. Please let me know 
if you have any questions about our comments.

Sincerely,

Eugene W. Hickok:

Signed by Eugene W. Hickok:

Enclosure:

[End of section]

Appendix III: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Kay E. Brown (202) 512-3674 (brownke@gao.gov)
Susan J. Lawless (206) 287-4792 (lawlesss@gao.gov):

Staff Acknowledgments:

In addition to the individuals named above, Robert B. Miller, 
Dianne L. Whitman-Miner, Shana B. Wallace, Tamara L. Fucile, 
Daniel A. Schwimer, Karyn I. Angulo, and Stanley G. Stenersen made key 
contributions to this report.



FOOTNOTES

[1] Mark Nord, Margaret Andrews, and Steven Carlson, Household Food 
Security in the United States, 2001 Washington, D.C.: U.S. Department 
of Agriculture, Economic Research Service, 2002.

[2] U.S. General Accounting Office, School Meal Programs: Few Instances 
of Food Borne Outbreaks Reported, but Opportunities Exist to Enhance 
Outbreak Data and Food Safety Practices, GAO-03-530 (Washington, D.C.: 
May 9, 2003) and School Meal Programs: Revenue and Expense Information 
from Selected States, GAO-03-569 (Washington, D.C.: May 9, 2003). 

[3] U.S. Department of Agriculture, Food and Nutrition Service, Office 
of Analysis, Nutrition and Evaluation, School Nutrition Dietary 
Assessment Study II, Final Report (SNDA-II), July 2001. For subsequent 
references to the same work: SNDA-II; (2) Centers for Disease Control 
and Prevention, School Health Policies and Programs Study 2000: A 
Summary Report, (SHPPS 2000) Journal of School Health, Volume 71, 
Number 7, September 2001. For subsequent references to the same work: 
SHPPS 2000; and (3) U.S. Department of Agriculture, Food and Nutrition 
Service, Office of Analysis, Nutrition and Evaluation, The School Meals 
Initiative Implementation Study, Third Year Report, June 2002.

[4] In addition, we visited one school and talked with a school food 
official in both Virginia and Washington State. 

[5] In school year 2002-03, USDA reimbursed participating schools $2.14 
for every free lunch meal provided, $1.74 for every reduced price lunch 
meal sold, and $0.20 for every other lunch meal sold. The rates are the 
minimum cash amounts reimbursed. USDA also provides higher amounts for 
districts with 60 percent or more children approved for free and 
reduced-price meals, districts in Hawaii and Alaska, and districts 
identified by states as having critical needs in order to ensure 
equitable distribution.

[6] P.L. No. 103-448, sec. 106 (1994).

[7] In National Soft Drink Ass'n. v. Block, 721 F.2d 1348 (D.C. Cir. 
1983), the Court of Appeals for the District of Columbia overturned the 
federal regulation in effect at the time prohibiting the sale of foods 
of minimal nutritional value anywhere in the school from the beginning 
of the school day until the last meal period. The court construed a 
1977 amendment to the Child Nutrition Act as allowing USDA to regulate 
the sale of competitive foods only in food service areas during meal 
periods. Following this decision, USDA amended its regulation to limit 
the prohibition of these foods to food service areas during meal 
periods.

[8] Mathematica Policy Research, Inc., The School Nutrition Dietary 
Assessment Study, School Food Service, Meals Offered, and Dietary 
Intakes, (SNDA-1), Oct. 1993. For subsequent references to the same 
work: (SNDA-I).

[9] According to USDA officials, the standard for sodium level used in 
SNDA-II is based on National Research Council recommendations.

[10] U.S. Department of Agriculture and U. S. Department of Health and 
Human Services, Nutrition and Your Health: Dietary Guidelines for 
Americans, 3rd edition, Washington, D.C. (1990).

[11] At the time SNDA-I was conducted, schools were not required to 
offer meals that were consistent with the Dietary Guidelines for 
Americans.

[12] SNDA-II.

[13] U.S. Department of Education, Office of Educational Research and 
Improvement, National Center for Education Statistics, Nutrition 
Education in Public Elementary School Classrooms, K-5, (Feb. 2000).

[14] SHPPS 2000.

[15] Leslie A. Lytle, Nutrition Education for School-aged Children, 
Journal of Nutrition Education, Vol. 27, No. 6, (Dec. 1995).

[16] SHPPS 2000.

[17] For more information on commercial activities in schools, see U.S. 
General Accounting Office, Public Education: Commercial Activities in 
Schools, GAO/HEHS-00-156 (Washington, D.C.: Sept. 8, 2000). 

[18] For more information on school meal revenues compared to expenses 
in school years 1996-97 through 2000-01, see U.S. General Accounting 
Office, School Meal Programs: Revenue and Expense Information from 
Selected States, GAO-03-569 (Washington, D.C.: May 9, 2003).

[19] In 1994, Congress mandated major changes to Title I of the 
Elementary and Secondary Education Act in response to concerns that 
Title I funding was not significantly improving the educational 
achievement of at-risk students. Under the 1994 reauthorization, states 
were required to adopt or develop challenging curriculum content and 
performance standards, assessments aligned with content standards, and 
accountability systems to assess schools' and districts' progress in 
raising student achievement. The No Child Left Behind Act of 2001 
augmented the assessment and accountability requirements that states 
must implement and increased the stakes for schools that fail to make 
adequate progress. For more information on state implementation of 
these requirements see U.S. General Accounting Office, Title I: 
Education Needs to Monitor States' Scoring of Assessments, GAO-02-393, 
(Washington, D.C.: April 1, 2002).

[20] USDA cautions that schools must take other issues into account 
when considering adding a salad bar including food safety practices 
associated with preparing and storing the salad bar items as well as 
proper student use. 

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