In fiscal year 2012,  the federal government spent $11.6 billion on the National School Lunch  Program, which served lunches to 31.6 million children on average each  month. 2.) USDA is  required to review state administration of the program, and states are  required to review SFA administration of the program. Specifically, to ensure that state  agencies provided training and technical assistance to help SFAs  implement the changes to the content of lunches, USDA allowed states to  postpone administrative reviews until school year 2013-2014.during school year 2012-2013, states were required to review  documentation submitted by SFAs and certify those SFAs determined to  be in compliance with the new lunch requirements. School Lunch Participation Declined by 1 Million Students in Recent Years, Likely Due to the Changes to Lunch Requirements and Other Factors

		Total School Lunch Participation Declined by 1 Million Students from School Years 2010-2011 through 2012-2013

Nationwide, participation in the National School Lunch Program declined  in recent years after having increased steadily for more than a decade. The decrease in  the total number of students eating school lunches during the last 2  school years was driven primarily by a decrease of 1.6 million students  paying full price for meals, despite increases in the number of students  eating school lunches who receive free meals. 7.) Almost all states reported that  student acceptance of the changes was challenging for at least some of  their SFAs during school year 2012-2013, a factor that likely affected  participation. Nationwide, SFAs Faced Challenges Implementing Lunch Changes, Though Some Challenges Will Likely Diminish Over Time

		Addressing Plate Waste, Managing Food Costs, and Planning Menus Challenged Many SFAs as They Implemented School Lunch Changes

As SFAs began implementing the new lunch requirements in school year  2012-2013, they faced several challenges implementing the lunch  changes. For example, most states reported that their SFAs faced  challenges with plate waste—or foods thrown away rather than consumed  by students—and food costs, as well as planning menus and obtaining  foods that complied with the new portion size and calorie requirements. While  USDA generally agreed with the recommendation, the department has  not yet taken action to address that issue. For example, fewer states reported that they  expect menu planning, including the required portion sizes for lunch  components and calorie ranges for lunches, to challenge their SFAs in  school year 2013-2014 than reported these areas as challenges in school  year 2012-2013. USDA’s Assistance Efforts Were Substantial, but Certain Aspects of USDA’s Guidance May Hinder State Oversight of Compliance

		USDA Provided a Substantial Amount of Guidance and Training in a Short Time, Which Was Both Useful and Challenging for States and SFAs

USDA provided a substantial amount of guidance and training to assist  states and SFAs in complying with the required changes to school lunch,  which states indicated was useful. In addition, the  documentation of issues has also provided federal and state officials with  information on areas for which additional assistance may be needed  across SFAs. In  another state, we obtained evidence that some of the lunch menus in an  SFA we visited may not have been fully in compliance with the new  requirements, though the SFA was certified and validated, and in two  additional certified SFAs we visited, we observed practices in schools that  were inconsistent with the new requirements.SFAs we visited had been certified to be in compliance with the new  requirements at the time of our site visits, the possible noncompliance  issues in three of these five SFAs indicate the difficulty of ensuring proper  implementation of the lunch changes in all of an SFA’s schools,  particularly during the first year that changes were required. Further, because the Healthy, Hunger-Free Kids Act of 2010  included two new provisions that relate to SFA financial management— those addressing paid lunch prices and revenue from foods sold outside  of the school meals programs—without effective oversight of SFA  financial management by states, neither states nor the federal  government will have assurance that SFAs are correctly implementing  these requirements. Recommendations for Executive Action

To improve program integrity, as USDA moves forward with its new  administrative review process, we recommend that the Secretary of  Agriculture direct the Administrator for the Food and Nutrition Service to  take the following actions:  clarify to states the importance of documenting compliance issues  found during administrative reviews and requiring corrective actions to  address them, and continue efforts to systematically assess all states’ needs for  information to improve their ability to oversee SFA financial  management and provide assistance to meet identified needs. Survey of States

To obtain information on state efforts related to implementation of the new  school lunch content and nutrition requirements, we conducted a national  survey of state child nutrition directors who oversee the National School  Lunch Program in the 50 states and the District of Columbia. We selected the pretest states to provide variation in state  school lunch program characteristics and geographic location. We also interviewed the eight state child nutrition  program directors overseeing these districts to gather information on  statewide lunch participation trends; SFA challenges, if any; and USDA  and state assistance with implementation of the changes.
Why GAO Did This Study

The National School Lunch Program served more than 31 million children in fiscal year 2012, in part through $11.6 billion in federal supports. The Healthy, Hunger-Free Kids Act of 2010 required USDA to update nutrition standards for lunches. USDA issued new requirements for lunch components--fruits, vegetables, grains, meats, and milk--and for calories, sodium, and fats in meals. USDA oversees state administration of the program, and states oversee local SFAs, which provide the program in schools. The changes were generally required to be implemented in school year 2012-2013. GAO was asked to provide information on implementation of the lunch changes.
GAO assessed (1) lunch participation trends, (2) challenges SFAs faced implementing the changes, if any, and (3) USDA's assistance with and oversight of the changes. To address these areas, GAO used several methods, including review of federal laws, regulations, and guidance; analysis of USDA's lunch participation data; a national survey of state child nutrition program directors; and site visits to eight school districts selected to provide variation in geographic location and certain school district and food service characteristics.

What GAO Found

Nationwide, student participation in the National School Lunch Program declined by 1.2 million students (or 3.7 percent) from school year 2010-2011 through school year 2012-2013, after having increased steadily for many years. This decrease was driven primarily by a decline of 1.6 million students eating school lunch who pay full price for meals, despite increases in students eating school lunch who receive free meals. State and local officials reported that the changes to lunch content and nutrition requirements, as well as other factors, influenced student participation. For example, almost all states reported through GAO's national survey that obtaining student acceptance of lunches that complied with the new requirements was challenging during school year 2012-2013, which likely affected participation in the program. Federal, state, and local officials reported that federally-required increases to lunch prices, which affected many districts, also likely influenced participation.
School food authorities (SFA) faced several challenges implementing the new lunch content and nutrition requirements in school year 2012-2013. For example, most states reported that SFAs faced challenges with addressing plate waste--or foods thrown away rather than consumed by students--and managing food costs, as well as planning menus and obtaining foods that complied with portion size and calorie requirements. SFAs that GAO visited also cited these challenges. However, both states and SFAs reported that they expect many of these areas will become less challenging over time, with the exceptions of food costs, insufficient food storage and kitchen equipment, and the forthcoming limits on sodium in lunches.
The U.S. Department of Agriculture (USDA) provided a substantial amount of guidance and training to help with implementation of the lunch changes and program oversight, but certain aspects of USDA's guidance may hinder state oversight of compliance. Starting in school year 2012-2013, USDA allowed states to focus their oversight of the lunch changes on providing technical assistance to SFAs rather than documenting instances of noncompliance and requiring corrective actions to address them. This assistance likely helped many SFAs move toward compliance with the new lunch requirements and become certified to receive increased federal reimbursements for lunches. However, evidence suggests this approach may have also resulted in some SFAs that were not fully meeting requirements being certified as in compliance. Without documentation of noncompliance and requirements for corrective actions, SFAs may not have the information needed to take actions to address these issues, and USDA may lack information on areas that are problematic across SFAs. Moving forward, USDA has been developing a new process for conducting program oversight, in part because of new statutory requirements. This new process adds requirements for reviewing SFA financial management, and many states reported a need for more guidance and training in this area. USDA has acknowledged that states' processes for reviewing this area have been inconsistent and sometimes inadequate in the past. While USDA has provided some assistance to states on the new requirements related to SFA financial management, until USDA has collected information from all states on their needs in this area, the department will not know if all states are fully prepared to oversee SFA financial management.

What GAO Recommends

To improve program integrity, GAO recommends that USDA clarify the need to document noncompliance issues found during state reviews of SFAs and complete efforts to assess states' assistance needs related to oversight of financial management. USDA generally agreed with GAO's recommendations.