The Healthy, Hunger-Free Kids Act of 2010  required USDA to update federal requirements for school lunches,  breakfasts, and to establish standards for competitive foods—foods sold  to children in schools other than through the school meals programs. 1.) USDA regulations also phase in requirements for sodium reductions in  lunches. 2.) 3.) The participation rate, which measures the  proportion of all students in schools that take part in the National School  Lunch Program who ate school lunches, also declined during this period,  falling from 62 percent in school year 2010-2011 to 58 percent in school  year 2013-2014. 4.) According to officials from four states, another factor that may have led to  lower participation among students paying full price for lunch is the  federally-required increase in the prices of paid lunches in certain  districts—also known as paid lunch equity. According to our analysis of USDA data, participation in the  School Breakfast Program grew by 1.4 million students (or 12 percent)  from school year 2010-2011 through school year 2013-2014, to a total of  13.5 million students. According to USDA data, the increases in School Breakfast Program  participation can be explained, in part, by program expansion. SFAs Continue to Report Challenges with New School Meals Requirements and Expressed Concern about Future Sodium Restrictions

		Some Challenges We Reported on Previously Have Persisted

SFAs and states reported that some of the challenges they have  experienced meeting the new school meals requirements have persisted  since school year 2012-2013, such as increased plate waste. Our lunch observations suggest that plate waste may be beginning to  decrease as students adjust to school meals that meet the new  requirements. Although there has been some progress, poor student acceptance of  certain foods is another longstanding challenge that SFAs continued to  report. Representatives  from four of the eight food companies we interviewed said they  anticipated problems with developing foods that would meet future  targets. An additional effort that may assist SFAs struggling with the  sodium reductions in the future is USDA’s training and peer-to-peer  mentoring program called “Team Up For School Nutrition Success,” which  aims to leverage successes from some SFAs by sharing best practices  with others that are struggling with specific aspects of implementing the  new nutrition requirements. SFAs and Schools Made Changes to Comply with the New Federal Competitive Food Standards and Faced Challenges with Procurement, Revenue, and Oversight

		SFAs and School Groups Had to Make Product Changes and Had Procurement Challenges

While many states and school districts had pre-existing policies on  nutrition standards for competitive food sales when the new federal  requirements were established, SFAs and school groups in seven of the  eight districts we reviewed reported that they had to make changes to the  competitive foods they offered for sale in school year 2014-2015 to  comply. However, at the same time, three of eight SFAs expressed  concerns that not all school groups were in compliance with the new  requirements and the consequences for noncompliance were unclear. The expansion of state oversight responsibility to include reviews of  competitive foods could help ensure compliance with the nutrition  standards, though some states reported that initial oversight of this area  has been challenging. USDA’s Assistance Has Included a Substantial Amount of Guidance and Other Efforts

Officials from several states and SFAs that we interviewed during school  year 2014-2015 indicated that USDA’s assistance on the new school  meals and competitive food requirements was helpful or has recently  improved; at the same time, some found the amount of USDA guidance  to be overwhelming. In  addition, two SFAs reported that USDA guidance on the changes has  improved over time; however, a state official also told us that USDA has  issued too much guidance, and it has overwhelmed SFAs. With the bulk of the changes to school meals and competitive foods  nutrition standards already required to be implemented, the need for  USDA to issue additional guidance on these changes should diminish in  future years, according to officials. In recognition of the challenges SFAs have faced while implementing the  new requirements, USDA has provided other types of assistance  intended to help clarify the regulations and guidance. In addition, the initiative offers monthly webinars for states and  SFAs on a wide variety of topics—including menu planning and sodium,  which are also made available online for later viewing. Appendix I: Scope and Methodology

	U.S. Department of Agriculture (USDA)

		Participation Data

To assess trends in school lunch and breakfast participation, we analyzed  USDA’s national data on meals served in the National School Lunch and  School Breakfast Programs from school year 2000-2001 through school  year 2013-2014. Site Visits

To gather information from the local level on implementation of the new  nutrition requirements for school meals and competitive foods, we  contacted the same eight school districts across the country that we had  visited as part of our prior study of implementation of the new school  lunch requirements in school year 2012-2013. We selected these school districts  because they provided variation across geographic location, district size,  and certain characteristics of the student population and district food  services.
Why GAO Did This Study

The Healthy, Hunger-Free Kids Act of 2010 required USDA to update nutrition standards for school lunches and breakfasts and add standards for other food sold in schools, known as competitive foods. In response, USDA set new nutrition requirements, including limits on calories, sodium, and fats. Previously, GAO reported on the implementation of changes to school lunches in school year 2012-2013. Since then, additional requirements for lunches have taken effect, as well as new requirements for breakfasts and competitive foods. GAO was asked to review implementation of the nutrition changes to school food.
GAO reviewed (1) recent trends in school meals participation, (2) challenges SFAs faced in implementing the new requirements for school meals, (3) challenges SFAs and districts faced in implementing new requirements for competitive foods, and (4) USDA assistance in implementing the changes.
GAO reviewed relevant federal laws, regulations, and guidance; analyzed federal school meals participation data from school years 2000-2001 through 2013-2014; reviewed implementation in the same eight school districts visited for the report on school year 2012-2013 lunch changes, selected to provide variation in geographic location and certain district and food service characteristics; and interviewed USDA and state officials, as well as food industry and stakeholder groups.

What GAO Found

Nationwide, participation in the National School Lunch Program declined by 1.4 million children (or 4.5 percent) from school year 2010-2011 through school year 2013-2014, to 30.4 million children. The participation rate of enrolled students also declined, from 62 to 58 percent. Seven of eight states that GAO interviewed reported that challenges with student acceptance of changes made to comply with new federal nutrition requirements contributed to the decrease. Also, four of eight states noted that recent required increases in the price of lunch may have decreased participation among some students. At the same time, nationwide participation in the breakfast program continued its trend of steady increases, which can be explained, in part, by program expansion into more schools.
The U.S. Department of Agriculture (USDA), states, and the eight School Food Authorities (SFAs) GAO reviewed, which administer meal programs in school districts, reported some ongoing challenges with meal requirements; however some SFAs noted success in certain areas. For example, five of eight SFAs, described continuing challenges with plate waste, that is, students taking required foods and then not eating them. However, officials in the other three, as well as GAO's mealtime observations across the two school years, suggest that plate waste may be decreasing in some SFAs. Also, five of the SFAs reported difficulty serving certain required food items in ways that appeal to students, though others reported some success. Regarding sodium, SFA, state, and food company officials expressed concerns about meeting future targets, which USDA plans to phase in over the next 8 years. To address these concerns, USDA is gathering information from SFAs and the food industry on progress toward reducing sodium levels in school meals.
New requirements for competitive foods—foods sold to students in schools other than through the school meals programs—also challenged SFAs and schools during school year 2014-2015. Six of eight SFAs reported difficulty procuring items that met the new requirements, particularly at the beginning of the school year. Also, four SFAs and two school groups selling competitive foods in the eight districts GAO reviewed reported decreased revenues due to lower student demand for products that comply with the requirements. In addition, SFA and state officials reported issues with ensuring compliance and providing oversight of these sales. To identify and help address such issues, USDA recently required states to begin including competitive foods in their periodic reviews of SFAs.
Officials from five states and four SFAs reported that USDA's assistance in implementing these changes has been helpful or improving over time; however, some SFAs noted problems with the amount or clarity of the guidance. USDA has initiated efforts to assist SFAs, such as by conducting webinars on a variety of topics, including menu planning. At the same time, officials from three of eight SFAs said USDA guidance on the new requirements—comprising nearly 4,700 pages issued from January 2012 through April 2015—has been challenging to keep up with. However, according to USDA, the substantial changes to nutrition standards have already occurred, and therefore, the need for additional guidance should decrease in future years. Moreover, USDA has provided other types of assistance that help clarify the guidance, including initiatives that facilitate the sharing of best practices and provide peer mentoring.

What GAO Recommends

GAO is not making any recommendations.