The program  provides nutritionally balanced low-cost or free lunches in participating  schools to about 31 million children each month. In fiscal year 2012, the federal  government spent over $11 billion on the National School Lunch  Program. Regarding the lunch components— fruits, vegetables, grains, meats, and milk—the Institute recommended  offering both fruits and vegetables daily, increasing whole grain-rich  foods, offering only fat-free and low-fat milk, and limiting the amount of  grains and meats/meat alternates served each week. The Eight SFAs We Visited Faced Several Challenges Implementing the New Lunch Requirements

		All Were Challenged by Meat and Grain Limits

Because regulations issued in January 2012 by USDA placed limits on  the amounts of meats/meat alternates and grains that can be included in  a school lunch, all eight SFAs we visited modified or eliminated some  popular menu items, leading to negative student reactions in some  districts. The grain maximums also affected popular lunch items, such as  sandwiches. For example, four  SFAs we visited said they met regularly with vendors during school year  2012-2013 as vendors worked to bring their products into compliance. In response to feedback from states and SFAs regarding operational  challenges caused by the meat and grain maximums, USDA lifted the  maximums temporarily. A few months later, in February 2013,  USDA provided the same flexibility for school year 2013-2014,  acknowledging that SFAs needed guidance to help with meal planning  and food procurement for the coming school year, as SFAs often plan  menus and order or contract for food beginning in the winter of the  previous school year. In May 2013, USDA officials told us that the  Department wanted to be responsive to the challenges they had heard  about, and they did not see a problem making the temporary change to  help with implementation because the meat and grain maximums and the  calorie maximums both accomplish the goal of addressing portion size,  making them somewhat redundant. SFA directors, food manufacturers, and other relevant industry  representatives indicated the need for a timely and permanent federal  decision on these maximums. Calorie Requirements for Middle and High Schools Also Challenged Some SFAs

Because the required calorie ranges for grades 6-8 and 9-12 do not  overlap, schools with students in both these grade groups faced  challenges complying with the calorie requirements. This creates a challenge for schools that include  students from both grade groups, including schools in two of the districts  we visited. One SFA director, whose district includes schools serving 7th  through 12th graders, noted that complying with both of the calorie range  requirements is particularly difficult when students in different grades use  the same serving lines and share a lunch period. USDA’s response to this issue, provided in part through the Department’s  guidance on menu planning under the new lunch requirements, has been  limited. Student Acceptance Has Been a Challenge to Some Extent

While all eight SFAs we visited expressed support for the goal of  improving the nutritional quality of lunches and felt the new requirements  were moving in that direction, all eight experienced various challenges  related to student acceptance of some of the foods served to comply with  the requirements. For  example, six districts mentioned student acceptance of whole grain  breads or pasta as being a challenge. Student participation in lunch has decreased to some extent in school  year 2012-2013, which is another indicator that student acceptance of  school lunches may have declined since the changes. SFAs Noted Concerns about the Proposed Competitive Foods Changes

In addition to the school lunch changes, the Healthy Hunger-Free Kids  Act of 2010 required that USDA specify and require nutrition standards for  all foods and beverages sold outside the school meals programs on the  school campus during the school day, which are commonly referred to as  competitive foods because they compete with school meal programs. Many students’ positive comments on healthy foods, their views  that school lunches generally provide such foods, and their consumption  of sizeable quantities of fruits and vegetables in the majority of schools  we visited indicate that acceptance of the new lunch requirements will  improve over time. While some of the challenges SFAs faced this year have been addressed  and others may become less difficult as time elapses, those caused by  the required weekly maximum amounts of meats and grains permitted in  lunches and the lack of overlap in the allowable calorie ranges for grades  6-8 and 9-12 likely will not. However, although USDA has acknowledged the need for a permanent  decision on the maximums, they have yet to provide one, hindering the  ability of school districts to plan menus, food purchases, budgets, staff  training, and student education because they do not know whether the  meat and grain restrictions will be reinstated in the future or not. In  addition, the requirements that lunches served to students in grades 6-8  provide different amounts of calories than lunches served to students in  grades 9-12—even in schools that serve students in both grade groups— is inconsistent with past practices, expert recommendations, and USDA’s  intent of simplifying the administration and operations of the school lunch  program. Recommendations

To improve SFAs’ ability to design menus that comply with the new lunch  requirements, we recommend that the Secretary of Agriculture: permanently remove the weekly meat/meat alternate and grain  maximums for school lunch defined in federal regulations, and modify federal regulations or guidance to allow school districts  flexibility in complying with the defined calorie ranges for schools with  students in both the grades 6-8 and 9-12 groups.
Why GAO Did This Study

The National School Lunch Program served 31.6 million children in fiscal year 2012, in part through $11.6 billion in federal supports. The most recent reauthorization of the program, the Healthy, Hunger-Free Kids Act of 2010 required that nutrition standards for school lunches be updated. As a result, USDA issued final regulations aimed at providing lunches high in nutrients and low in calories that better meet the dietary needs of school children and required that they be implemented beginning in school year 2012-2013. The new rules provide detailed requirements for meal components--fruits, vegetables, grains, meats, and milk; update requirements for calories, sodium, and fats; and require that each student's lunch contain a fruit or vegetable. To provide information on challenges that school districts have faced, this testimony draws on work GAO conducted as part of its ongoing study of implementation of the changes. Specifically, GAO reviewed relevant federal laws, as well as USDA regulations, guidance, and studies; interviewed USDA officials and groups of food service officials and relevant industry representatives; and visited eight school districts. The districts varied by geographic location, size, and certain student and food services characteristics.

What GAO Found

School districts faced several challenges implementing the new lunch requirements in school year 2012-2013, according to the eight districts GAO visited and food service and industry officials GAO interviewed from across the country; and the U.S. Department of Agriculture's (USDA) response to some of these challenges has been limited. For example, because USDA regulations restrict the amounts of meats and grains that can be served in school lunches each week, all eight districts GAO visited needed to modify or eliminate popular menu items. These changes sometimes led to negative student reactions. The meat and grain restrictions also led to smaller lunch entrees, making it difficult for some schools to meet minimum calorie requirements for lunches without adding items, such as gelatin, that generally do not improve the nutritional quality of lunches. In response to feedback from states and districts regarding operational challenges caused by the meat and grain restrictions, USDA lifted the limits temporarily, first for the remainder of school year 2012-2013 and then for school year 2013-2014. USDA officials said they did not see a problem making the temporary changes to help with implementation because the limits on meats and grains and the limits on the calories in lunches are somewhat redundant, as both address portion size. However, because the change was seen as temporary, the eight districts GAO visited made only marginal changes to their menus. Rather, several district food services officials, as well as relevant industry representatives, indicated the need for a permanent federal decision on these restrictions, which USDA has also acknowledged.
The calorie range requirements for lunches also challenged some districts, particularly those with schools that include students from both grades 6-8 and 9-12. Because the required lunch calorie ranges for these two grade groups do not overlap, districts with such schools face difficulties planning menus and serving lunches that comply with both requirements. For example, one food services official, whose district includes schools serving 7th through 12th graders, developed menus with calorie counts between the grades 6-8 maximum and the grades 9-12 minimum, leaving the lunches out of compliance with both sets of restrictions. Although USDA has acknowledged that menu planning in such schools can be challenging, USDA's current guidance does not provide these districts flexibility to assist their efforts to comply. Rather, guidance suggests that students from different grades be provided with different lunches, a solution that may be impractical in schools in which students of different grades share lunch periods and serving lines.
Although the eight districts GAO visited expressed support for the improvements to the nutritional quality of school lunch, they reported additional challenges meeting the new requirements, such as student acceptance, food waste, costs, and participation. For example, USDA requires that meals include whole grain-rich products and certain vegetables, but most districts noted that obtaining student acceptance of foods like whole grain pasta and beans has been challenging. If students do not accept these items, the result may be increased food waste or decreased participation in the lunch program, which were concerns in most districts GAO visited. However, student acceptance of the changes will likely improve over time, as indicated by their positive comments about healthy food and consumption of fruits and vegetables in most districts GAO visited.

What GAO Recommends

GAO recommends that USDA permanently remove the meat and grain maximum requirements and allow flexibility to help districts comply with the lack of overlap in the calorie ranges for grades 6-8 and 9-12 lunches. USDA generally agreed with GAO's recommendations.