(Nutrition and Diet Research Progress) Jared N. Denham - Competitive Foods in Schools - Revenue Issues and Nutrition Standards (2013, Nova Science Pub Inc) PDF

NUTRITION AND DIET RESEARCH PROGRESS
COMPETITIVE FOODS
IN SCHOOLS
REVENUE ISSUES AND NUTRITION

STANDARDS FOR SNACKS
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NUTRITION AND DIET RESEARCH PROGRESS
COMPETITIVE FOODS
IN SCHOOLS
REVENUE ISSUES AND NUTRITION

STANDARDS FOR SNACKS
JARED N. DENHAM
EDITOR
New York
Copyright © 2013 by Nova Science Publishers, Inc.
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CONTENTS
Preface vii
Chapter 1 Nutrition Standards for Competitive Foods in Schools:
Implications for Foodservice Revenues 1
Joanne F. Guthrie, Constance Newman,
Katherine Ralston, Mark Prell
and Michael Ollinger
Chapter 2 School Meal Programs: Competitive Foods Are
Widely Available and Generate Substantial
Revenues for Schools 59
United States Government Accountability Office
Chapter 3 Competitive Foods and Beverages in U.S. Schools:
A State Policy Analysis 115
Centers for Disease Control and Prevention
Chapter 4 Smart Snacks in Schools: USDA’s ''All Foods
Sold in Schools'' Standards 141
United States Department of Agriculture
Chapter 5 “Smart Snacks in School” Nutrition Standards
Interim Final Rule Questions and Answers 145
U.S. Department of Agriculture
Chapter 6 Nutrition Standards for All Foods Sold in School 151
Index 157
PREFACE
Across America, meals provided through USDA’s National School Lunch

Program (NSLP) and School Breakfast Program (SBP) supply most of the
foods and beverages obtained by children at school. Most schools also sell
competitive foods, or “à la carte” items, alongside USDA school meals, in
vending machines, or in school stores and snack bars, with proceeds going to
the school foodservice or fundraising school groups. These foods have been
widely criticized as being of low nutritional value, undercutting public efforts
to improve children’s diets and prevent obesity. The Healthy, Hunger-Free
Kids Act of 2010 requires schools that offer USDA school meals to limit
competitive foods to those that meet updated nutrition standards, under
development by USDA’s Food and Nutrition Service (FNS). Limiting the
types of competitive foods available for sale may result in lost revenue for
school foodservices, which depend to varying degrees on this revenue stream.
Because USDA school meal programs are a part of the Nation’s nutrition
safety net, the contribution that competitive food revenues make to
foodservices serving economically vulnerable student populations is of
particular interest. This book examines how updated nutrition standards for
competitive foods might affect competitive food availability, and the
implications for foodservice revenues.
Chapter 1 – USDA’s National School Lunch and School Breakfast
Programs supply most of the foods and beverages obtained by children in U.S.
schools. Many schools also sell supplemental items, often called “competitive
foods.” The Healthy, Hunger-Free Kids Act of 2010 required USDA to set
nutritional requirements for competitive foods served by schools that also offer
USDA school meals, and this could diminish revenue to local school
foodservices. This report uses data from two national surveys of schools and
viii Jared N. Denham
School Food Authorities to examine competitive food selections and their

contribution to school foodservice revenues. Most competitive foods selected
by students in 2005 were of low nutritional value. The amount of revenue
obtained from these foods varied widely, but most foodservices earned less
than 12 percent of revenues from competitive foods. School foodservices with
high competitive food revenues typically were located in more affluent
districts and served fewer students receiving free and reduced-price lunches.
Secondary (middle and high) schools received much more revenue from
competitive foods than did elementary schools.
Chapter 2 – Recent increases in child obesity have sparked concerns about
competitive foods—foods sold to students at school that are not part of
federally reimbursable school meals. The nutritional value of these foods is
largely unregulated, and students can often purchase these foods in addition to
or instead of school meals. In our April 2004 report on competitive foods
(GAO-04-673), the authors reported that several states had enacted
competitive food policies that were more restrictive than federal regulations.
However, these policies differed widely in the type and extent of restrictions.
In addition, it was unclear how and to what extent states were monitoring
compliance with these policies. GAO was also asked to provide a national
picture of competitive foods in schools, as well as strategies that districts and
schools themselves are taking to limit the availability of less nutritious
competitive foods. This report provides information from two nationally
representative surveys about the prevalence of competitive foods in schools,
competitive foods restrictions and groups involved in their sale, and the
amounts and uses of revenue generated from the sale of competitive foods. It
also provides information about strategies schools have used to limit the
availability of less nutritious competitive foods, based on visits to a total of six
school districts in California, Connecticut, Mississippi, Missouri, and South
Carolina.
Chapter 3 – Since 1980, the prevalence of obesity among U.S. children
and adolescents has tripled, and today 19.6% of children aged 6–11 years and
18.1% of adolescents aged 12–19 years are categorized as obese. Because
youth spend a significant amount of their day in school, it is an ideal venue to
promote obesity prevention efforts. A growing body of research has found that
the school food environment is associated with youth dietary behaviors and
obesity.
Schools can play a critical role by establishing a safe and supportive
environment with policies and practices that sustain healthy behaviors. In
Preface ix
addition, schools provide opportunities for youth to learn about and practice
healthy eating and physical activity.
U.S. students are exposed to a broad range of foods and beverages through
reimbursable school meals, à la carte lines, vending machines, school stores,
classroom parties, fundraisers, and other school events. Nutrition standards for
federally reimbursable school meals are regulated by the U.S. Department of
Agriculture’s National School Lunch Program and School Breakfast Program.
Chapter 4 – USDA recently published practical, science-based nutrition
standards for snack foods and beverages sold to children at school during the
school day. The standards, required by the Healthy, Hunger-Free Kids Act of
2010, will allow schools to offer healthier snack foods to children, while
limiting junk food. The health of today’s school environment continues to
improve. Students across the country are now offered healthier school lunches
with more fruits, vegetables and whole grains. The Smart Snacks in School
standards will build on those healthy advancements and ensure that kids are
only offered tasty and nutritious foods during the school day.
Smart Snacks in School also support efforts by school food service staff,
school administrators, teachers, parents and the school community, all working
hard to instill healthy habits in students.
Chapter 5 – The new standards will allow schools to offer healthier snack
foods for our children, while limiting junk food served to students. Students
will still be able to buy snacks that meet common-sense standards for fat,
saturated fat, sugar, and sodium, while promoting products that have whole
grains, low fat dairy, fruits, vegetables or protein foods as their main
ingredients.
It is important to note that USDA has no role in regulating foods brought
from home. The standards do not apply to any foods brought to school in
bagged lunches, or for birthday parties and special events, including after-
school bake sales and fundraisers.
Nearly one third of children in America are at risk for preventable diseases
like diabetes and heart disease due to being overweight or obese. If left
unaddressed, health experts tell us that this generation may be the first to live
shorter lives than their parents.
Students across the country are now getting healthier school lunches with
more fruits and vegetables, whole grains, and low-fat dairy based on scientific
recommendations for nutrition. Yet for most teens and a growing percentage
of elementary students, items offered a la carte and in vending machines still
lack healthy options. Many students consume at least one snack food a day at
school.
x Jared N. Denham
Parents are working hard to ensure their children grow up healthy and
their efforts should not be undone when their kids go to school. Our children’s
ability to learn in the classroom and reach their fullest potential depends on
what we do right now to secure their future.
Chapter 6 – This chapter describes nutrition standards for all foods sold in
school.
In: Competitive Foods in Schools ISBN: 978-1-62948-006-0
Editor: Jared N. Denham © 2013 Nova Science Publishers, Inc.
Chapter 1
NUTRITION STANDARDS FOR COMPETITIVE

FOODS IN SCHOOLS: IMPLICATIONS FOR
FOODSERVICE REVENUES*
Joanne F. Guthrie, Constance Newman,

Katherine Ralston, Mark Prell and Michael Ollinger
ABSTRACT
USDA’s National School Lunch and School Breakfast Programs
supply most of the foods and beverages obtained by children in U.S.
schools. Many schools also sell supplemental items, often called
“competitive foods.” The Healthy, Hunger-Free Kids Act of 2010
required USDA to set nutritional requirements for competitive foods
served by schools that also offer USDA school meals, and this could
diminish revenue to local school foodservices. This report uses data from
two national surveys of schools and School Food Authorities to examine
competitive food selections and their contribution to school foodservice
revenues. Most competitive foods selected by students in 2005 were of
low nutritional value. The amount of revenue obtained from these foods
varied widely, but most foodservices earned less than 12 percent of
revenues from competitive foods. School foodservices with high
competitive food revenues typically were located in more affluent
*
This is an edited, reformatted and augmented version of United States Department of
Agriculture, Economic Research Service, Economic Information Bulletin Number 114,
dated June 2013.
2 Joanne F. Guthrie, Constance Newman, Katherine Ralston et al.
districts and served fewer students receiving free and reduced-price

lunches. Secondary (middle and high) schools received much more
revenue from competitive foods than did elementary schools.
A REPORT SUMMARY FROM THE ECONOMIC

RESEARCH SERVICE
Across America, meals provided through USDA’s National School Lunch
Program (NSLP) and School Breakfast Program (SBP) supply most of the
foods and beverages obtained by children at school. Most schools also sell
competitive foods, or “à la carte” items, alongside USDA school meals, in
vending machines, or in school stores and snack bars, with proceeds going to
the school foodservice or fundraising school groups. These foods have been
widely criticized as being of low nutritional value, undercutting public efforts
to improve children’s diets and prevent obesity. The Healthy, Hunger-Free
Kids Act of 2010 requires schools that offer USDA school meals to limit
competitive foods to those that meet updated nutrition standards, under
development by USDA’s Food and Nutrition Service (FNS).
What Is the Issue?
Limiting the types of competitive foods available for sale may result in
lost revenue for school foodservices, which depend to varying degrees on this
revenue stream. Because USDA school meal programs are a part of the
Nation’s nutrition safety net, the contribution that competitive food revenues
make to foodservices serving economically vulnerable student populations is
of particular interest. This report examines how updated nutrition standards for
competitive foods might affect competitive food availability, and the
implications for foodservice revenues.
What Are the Findings?
Desserts, sweetened beverages, salty snacks, and candy made up more

than half of competitive items selected by elementary and secondary school
students in 2005. Most (80-90 percent) of the competitive food and beverage
items selected by students would not fully meet updated nutrition standards,
Nutrition Standards for Competitive Foods in Schools 3
which would shift purchases from items high in fat, saturated fat, sugars, and
sodium to foods featuring whole grains, low-fat dairy, fruits, and vegetables.
One-third of elementary students consumed at least one competitive food
on a typical school day in 2005, whereas 53 percent of secondary students did.
Secondary students also consumed more competitive items than did
elementary students. Average annual competitive revenues for elementary
schools were about one-sixth those of middle schools and one-ninth those of
high schools. At both the elementary and secondary school levels, school
foodservices in more affluent districts obtained more revenues from
competitive foods on a per-student basis.
School Food Authorities (SFAs), the foodservice management units for
school districts, reported obtaining, on average, 12 percent of revenues from
competitive foods in 2002-2003, a period in which there were few nutritional
restrictions on competitive foods. Ten percent of SFAs received 36 percent or
more of their revenues from competitive foods, which was attributable both to
higher competitive food revenues and lower revenues from USDA school
meals. SFAs with higher shares of competitive food revenue typically were
located in more affluent districts and served fewer low-income students
receiving free and reduced-price meals than did schools with low competitive
food revenues. They also were more common in suburban, rather than urban or
rural, districts and in the Northeast, Mid-Atlantic, and Midwest.
Establishing nutrition standards for foods sold at school in competition
with the USDA meals should provide nutritional benefits, especially to
secondary-school students and in the typically suburban, more affluent SFAs
that obtain large shares of revenue from competitive foods and have low
school meal participation. There may be additional benefits to lowering the
profile of competitive foods in schools. Eliminating less nutritious competitive
foods may also support efforts to improve the quality of USDA school meals.
One study found NSLP lunches to be lower in fat in schools with no à la carte
and vending. In the competition for student food spending, the absence of
unhealthy alternatives may leave school foodservices more free to offer
healthier meals that meet Federal nutrition standards.
For school foodservices concerned about covering their expenses, the
challenge will be to adapt to new standards and develop new strategies for
maintaining revenues in a healthier school nutrition environment. The
challenge is most pronounced in SFAs receiving a large proportion of
revenues from competitive foods. Higher school food-service revenues from
competitive foods were associated with lower USDA lunch participation,
suggesting that competitive food revenues may displace meal participation and
associated revenue. In SFAs where competitive food revenues make up a

larger share of overall revenues, foodservice managers may be apprehensive
about nutrition-mandated changes in offerings. Such SFAs will be especially
interested in strategies for maintaining revenues when nutrition standards for
competitive foods are implemented.
To offset revenue losses from removal of competitive foods that fail to
meet nutrition standards, school foodservices can (1) seek out healthier
competitive food options to replace those currently sold, or (2) re-emphasize
their “core business” by expanding participation in school meals. For both
strategies, appropriate pricing is key. The Healthy, Hunger-Free Kids Act of
2010 addressed pricing of meals and competitive foods, and new regulations
based on this act may have important effects on revenues obtained both from
USDA school meals and from healthier competitive foods.
How Was the Study Conducted?
This study made use of two national surveys conducted on behalf of FNS.
Nationally representative school- and student-level data collected in 2004-05
were obtained from the School Nutrition Dietary Assessment III (SNDA-III),
whereas the School Food Authority Characteristics Study (SFACS) provided
school foodservice revenue and other data at the school district level from
2002-03. The SFACS sample was designed to generate national and regionally
representative estimates, and although now a decade old, is still the most
recent source for such data. At both the school and the SFA level, we examine
the association of school foodservice competitive revenues with (1) the socio-
economic environment in which schools and SFAs operate; (2) school meal
program characteristics like the average price charged for a full-price lunch;
and (3) State and local characteristics that influence the school environment in
which the foodservice operates.
CONGRESS MANDATES UPDATE OF NUTRITION

STANDARDS FOR COMPETITIVE FOODS
Across America, lunches and breakfasts provided through USDA’s
National School Lunch Program (NSLP) and School Breakfast Program (SBP)
supply most of the foods and beverages obtained by children at school. The
majority of schools also sell “competitive foods,” a general term for foods and
beverages sold in schools and that are not part of USDA school meals. They
are most commonly sold in the cafeteria alongside USDA school meals, where
they are known as “à la carte” items. They are also frequently sold in vending
machines and less frequently in other locations such as school stores and snack
bars, with profits sometimes going to the school foodservice or more often to
other school groups. Competitive foods are consumed by 40 percent of public
school students on a typical day (Fox et al., 2009).
USDA school meals are required to meet nutrition standards. These
standards were recently updated, as part of the Healthy, Hunger-Free Kids Act
of 2010 (USDA, 2011), to conform to the most up-to-date nutrition guidance
and to address concerns about childhood obesity. Meals now include more
whole fruit, dark green and red/orange vegetables, and whole grains.
While USDA meals are held to nutrition standards, the nutritional content
of competitive foods is minimally regulated. As concerns about child nutrition
and obesity have risen, the nutritional content of competitive foods has
become an issue (Kids Safe & Healthful Foods Project, 2012a). Most of the
competitive foods and beverages favored by children are “low-nutrient,
energy-dense” (LNED) foods, which are high in fat, sugars, or sodium, and
deficient in the fruits, vegetables, whole grains, fiber, and nutrients that are
underconsumed by U.S. children (USDHHS and USDA, 2011).
Section 208 of the Healthy, Hunger-Free Kids Act of 2010 requires USDA
to align nutrition standards for competitive foods with the Dietary Guidelines
for Americans. These standards must be met by all competitive foods sold at
school at any time during the school day (with special exemptions for
occasional school-sponsored fundraisers such as bake sales). USDA’s Food
and Nutrition Service (FNS) published in February 2013 a proposed rule
(USDA, FNS, 2013) of nutrition standards based on those developed by the
Institute of Medicine (IOM, 2007), allowing 60 days for comment. After the
final rule is published, schools will be given 1 year to implement the
regulations.
Updated nutrition standards for competitive foods would shift
schoolchildren’s purchases from foods and beverages high in overconsumed
food components such as fat, saturated fat, sugars, and sodium to foods lower
in these components and featuring whole grains, lowfat dairy, fruits, and
vegetables. Implementing these standards may affect the revenues and costs of
school foodservices.
Views on the financial effects of competitive food standards differ. Some
maintain that more stringent standards for competitive food could jeopardize
the financial viability of school food-services (Rinaldi, 2008; Greves and

Rivara, 2006). School foodservices that participate in USDA meal programs
are required to be nonprofit; however, many localities expect them to cover
their operational costs. This requires a delicate balancing of revenues and
costs, and for a large share of schools, revenues fall short of costs (USDA,
FNS, 2008). School foodservices must balance nutrition, student participation,
and meal cost to achieve nutrition and food security goals while covering
operational costs (Ralston et al., 2008). Some school foodservices contend that
the sale of competitive foods is necessary to maintain financial solvency (U.S.
GAO, 2005). Poppendieck (2010) quotes one school foodservice director as
saying, “We need to sell à la carte to be financially sound.”
In contrast, others question whether competitive food revenues actually
improve the net financial status of school foodservices because competitive
foods entail their own expenses and can reduce NSLP meal participation and
the associated revenues (Peterson, 2011). Several school foodservices have
reduced or discontinued competitive foods while simultaneously promoting
NSLP meal participation, with one director saying “I recommend elimination
of à la carte for anyone who wants to see their program grow—both in
participation and revenue” (Kavanaugh, 2010).
The effect of competitive food standards on a school foodservice’s
finances can depend, in part, on what steps the school foodservice takes to
adapt to healthier competitive offerings and/or promote the NSLP meal.
Student responses to healthier competitive foods—that is, whether they
continue to buy competitive items, shift to the NSLP meal, or bring food from
home or other outside sources— may vary depending on age, their household
economic conditions, or other factors.
This report examines how updated nutrition standards for competitive
foods might affect competitive food availability, and the implications for
foodservice revenues. It uses nationally representative data on school food
offerings, student selections, and foodservice revenues to estimate the
percentage of competitive food items that would or would not meet nutrition
standards. It examines student and school characteristics associated with
higher school foodservice revenues from competitive foods.
School-level foodservices are part of a School Food Authority (SFA),
usually a district-level unit that oversees foodservice operations and manages
the overall foodservice budget, consolidating revenues and submitting claims
for meal reimbursements to USDA. Using a national survey of SFAs, this
report examines the contribution of competitive food revenues to the SFA as a
share of SFA total revenues and how those shares relate to SFA
characteristics. Results should be useful to program and policy officials at

Federal, State, and local levels as they implement nutrition standards
governing competitive foods, allowing them to target and guide school
foodservices that are likely to be most in need of assistance.
BACKGROUND
Growth of Competitive Foods in U.S. Schools
Since the beginning of the National School Lunch Program (NSLP) in

1946, snacks and other food items have been sold in many schools
(Poppendieck, 2010). At first, the nutritional content of these foods was
viewed as purely a local issue. Concern about their nutritional quality and
detrimental effects on school meal consumption led to efforts to regulate sales
of competitive foods at the Federal level (Poppendieck, 2010; USDA, 2001;
U.S. GAO, 2005).
In 1977, the Child Nutrition Act was amended to empower USDA to limit
sales of foods that competed with USDA school meals. From 1980 to 1983,
USDA regulated the sale of foods sold anywhere in school until after the last
meal period. This blanket prohibition was challenged, and in National Soft
Drink Association vs. Block (1983), the Court of Appeals for the District of
Columbia ruled that USDA’s power should be limited to regulation of
competitive foods sold in the area where USDA meals were being served
during mealtimes (U.S. GAO, 2005). Current USDA regulations prohibit sale
of “foods of minimal nutritional value” in the foodservice area during meal
periods. These prohibited items are narrowly defined (CFR, 2011) and include
sugary items such as soft drinks, chewing gum, sugary candies like
marshmallows, and popsicles. Under this regulation, many high-energy-
density snacks and sweets such as fried chips, cakes, and chocolate candy are
still allowed.
In 2005, à la carte items were offered in the cafeteria at lunch in 92
percent of secondary schools, compared to 76 percent of elementary schools.1
When excluding the schools that offered only milk as an à la carte item, the
share of elementary schools with à la carte offerings fell to 32 percent.
Competitive food offerings were more varied in secondary schools. More than
half of secondary schools offered à la carte entrees, making it easy to
substitute competitive foods for the NSLP meal. Vending was relatively
uncommon in elementary schools (27 percent of schools) and ubiquitous in
secondary schools (87 percent of middle schools; 98 percent of high schools

(USDA, 2007a)).
Availability of specific competitive food items varied from school to
school. In 2005, about as many schools offered juice and water as sugary or
caffeine-containing beverages (USDA, 2007a). Fresh fruit was the most
widely available healthy choice among à la carte items, obtainable in approxi-
mately 40 percent of secondary schools, whereas cookies and chips were
available in more than half of them. Ice cream and cake-type desserts were
also obtainable in one-third or more of secondary schools (USDA, 2007a).
Nutritional Impacts of Competitive Foods
Competitive foods could have negative effects on children’s diets either

by substituting for a healthier lunch, reducing diet quality, or contributing
excess calories above the standard lunch. Using nationally representative data
from the 2004-05 school year, collected as part of USDA’s School Nutrition
Dietary Assessment III (SNDA-III), Fox et al. (2009) report that students who
ate competitive foods obtained an average of 277 calories per day from those
foods. Low-nutrient, energy-dense (LNED) foods and beverages contributed
177—or 64 percent—of those calories.
Among children who did not eat the NSLP lunch, 45 percent ate
competitive foods. Of those who ate the NSLP lunch, 36 percent also ate
competitive foods, which may crowd out some lunch items if, for example,
children eat chips or candy instead of the vegetables or fruit provided as side
items with the meal. Marlette et al. (2005) found that students who purchased
competitive foods along with the school lunch ate significantly less of their
fruit and several other foods, compared to students who only bought lunch. If
children do eat the complete lunch, the extra calories from LNED competitive
foods may contribute to obesity, although the link is not definitive (Taber et
al., 2012; Van Hook and Altman, 2012: Datar and Nicosia, 2012; Anderson
and Butcher, 2006).
Policy Actions to Improve Competitive Foods
As part of the Child Nutrition and WIC Reauthorization Act of 2004 (P.L.
108-265), Congress required that school districts participating in the NSLP
develop wellness policies that addressed the nutritional quality of all foods
available in schools, not just USDA meals (USDA, 2005). However, the
content of the wellness policies was left to local discretion—schools could
restrict less nutritious competitive foods or not. Similarly, there were no
requirements to assess compliance with any policies established.2
Competitive Food Revenues
On average across the country, revenues from competitive foods are far
smaller than those from USDA-funded school meals. Nationwide,
approximately 75 percent of school foodservice revenues were obtained from
USDA subsidies and student payments for USDA meals in 2005 and 9 percent
came from State and local funding, according to USDA’s School Lunch and
Breakfast Cost Study II (USDA, 2008). The remaining 16 percent came from
miscellaneous revenue, which included à la carte sales in the cafeteria, any
vending machines revenues, and all other miscellaneous revenues, such as
meals sold to adults, catering, etc. Competitive food sales vary considerably
among schools. Approximately one-quarter of elementary schools sold no
competitive foods in 2005 (Fox et al., 2009). Only 3 percent of middle schools
had no competitive foods, and virtually all high schools offered them.
Competitive foods have been reported to be a large portion of foodservice
sales and revenues in some schools. Responding to a small study conducted by
the U.S. General Accountability Office, one school foodservice director said
that his district generated nearly half its revenue through competitive food
sales (U.S. GAO, 2005).
DATA
USDA’s School Nutrition Dietary Assessment Study (SNDA)-III
For student and school-level analyses, we use data from the School
Nutrition Dietary Assessment Study III (SNDA-III). SNDA-III was conducted
by Mathematica Policy Research, Inc. (Mathematica), under contract with
USDA’s Food and Nutrition Service (FNS). It provides nationally
representative data on public schools that participate in the National School
Lunch Program and the students in grades 1-12 who attend those schools
(USDA, 2007c). Data were collected from 397 schools and 2,314 students in
the spring of 2005. Students identified each food/beverage item they selected
and where it was obtained (e.g., cafeteria line, vending machine, etc.).
Mathematica identified foods and beverages as being from USDA school
meals or competitive sources (see Fox et al., 2009, for details of the
methodology). Data on foodservice revenues, meal participation, and related
variables were obtained from questionnaires administered to school
foodservice managers. Information on vending by non-school foodservice
entities was obtained from questionnaires administered to school principals.
School Food Authority Characteristics Survey (SFACS)
For the SFA-level analysis, we use data from the School Food Authority
Characteristics Survey (SFACS), a nationally representative survey of SFAs
that collected information on SFA revenues and costs for school year 2002-03.
The survey was conducted by Abt Associates and Mathematica on behalf of
USDA’s FNS. It provides the most recent SFA financial data from a sample
that can generate estimates for each of the seven regions defined by FNS
(Northeast, Mid-Atlantic, Midwest, Mountain, Southeast, Southwest, and
West). A subset of 1,432 SFAs participated in the SNDA-III, providing
information on student enrollment, SFA revenues, and their sources (such as
USDA reimbursements for NSLP/SBP meals, student payments for USDA
meals, and student payments for competitive foods). The SFACS also contains
information on school district enrollment and demographic/wealth
characteristics drawn from the National Center for Education Statistics
Common Core of Data and the U.S. Census Bureau.
METHODS
To illustrate how implementation of nutrition standards for competitive
foods might affect school foodservice revenues, we assessed the types of
competitive foods and beverages most often selected by students in 2005
versus those that would be allowed under more stringent nutrition standards.
Because updated standards have not been finalized, we examined several
options, based on the IOM report Nutrition Standards for Foods in School:
Leading the Way to Healthier Youth (2007) (see box, “Foods and Beverages
That Meet IOM ‘Tier 1’ Nutrition Standards”). That report is the most widely
accepted source of expert guidance on the appropriate nutritional content of
competitive foods and underlies the nutrition standards proposed by FNS.
One “competitive foods” option estimated foods eligible for sale applying
the IOM Tier 1 standards as closely as possible, and the other two were less
restrictive, incorporating some alternative options proposed for consideration
(USDA, FNS, 2013). One allows sale of à la carte items also sold as part of the
reimbursable meal if they meet IOM-based criteria limiting fat and sugars, and
the second option allows à la carte sales of any foods that are part of the
reimbursable meal. Both options allow larger sizes of beverages and a wider
range of permissible beverages for sale in high schools, including flavored
waters, caffeinated beverages and low-calorie beverages such as diet sodas
(see Appendix B). SNDA-III does not provide the purchase price for each
selection; however, by examining the share of selected items that would be
purchasable versus disallowed, we can estimate the potential effects of
competitive food standards on student selections and, ultimately, on revenues.
Using SNDA-III data, we estimate annual school foodservice competitive
food revenues on a per-school basis, and on a per-student, per-school basis to
adjust for differences in school size. We include à la carte revenues and any
income the foodservice authority received from vending machines (in most
schools, vending revenues go to the school or other non-SFA groups, but there
are some in which the school foodservice obtained revenue from vending).3 À
la carte and vending revenues are converted to annual revenues based on a
180-day school year. This annual value is divided by the school’s average
daily attendance to arrive at per-student estimates.
We examine competitive food revenues from elementary and secondary
(middle and high) schools separately because of differences in student and
school characteristics (USDA, 2007a). Older students are expected to have
more discretionary funds and freedom with which to purchase foods and
beverages. For each subgroup of schools, we compare school foodservice
competitive food revenues on the basis of (a) the socioeconomic environment
in which the school foodservice operates, since revenue losses could be of
particular concern for school foodservices located in low-income districts
and/or serving primarily low-income children (Kids Safe & Healthful Foods
Project, 2012a), (b) school meal program characteristics like average price for
full-price lunch, and (c) State and local (district or school-level) characteristics
(e.g., reimbursements to SFAs) that influence the school environment (see
Appendix A). We categorize schools by revenue quartile in order to create
profiles of schools with lower and higher revenues from competitive foods.
The data are weighted using school-level sampling weights to obtain
nationally representative estimates (StataCorp., 2011). The SFA-level analysis
investigates competitive food revenues as a share of SFA revenues. This
measure is based on annual foodservice revenues for school year 2002-03, as
reported by the SFA director. Revenues are categorized according to source:
“student à la carte” and “other food sales, e.g. vending” are combined and used
as our measure of SFA competitive food revenues. We categorize SFAs by
percentage of revenue obtained from competitive foods and examine
associated socioeconomic and demographic characteristics, meal program
characteristics, and State characteristics (see Appendix A).
Foods and Beverages That Meet Institute of Medicine “Tier 1” Nutrition Standards1
Foods Beverages
Tier 1 foods are fruits, vegetables, whole Tier 1 beverages are:
grains, and related combination products2
and nonfat/low-fat dairy that are limited to • Water without flavoring, additives,
200 calories or less per portion as packaged or carbonation.
and contain: • Low-fat (1-percent milk fat) and
nonfat milk (in 8-oz portions):
• No more than 35 percent of total • Lactose-free and soy beverages
calories from fat. are included
• Less than 10 percent of total calories • Flavored milk with no more than
from saturated fats. 22 g of total sugars per 8-oz
• Zero trans fat (< 0.5 g per serving). portion.
• 35 percent or less of calories from • 100-percent fruit juice in 4-oz
total sugars, except for yogurt with no portion as packaged for
more than 30 g of total sugars, per 8- elementary/middle school and 8-oz
oz portion as packaged. (2 portions) for high school.
• Sodium content of 200 mg or less per • Caffeine-free, with the exception of
portion as packaged. trace amounts of naturally occurring
caffeine substances.
Á la carte entrée items that meet fat and
sugar limits as listed above and:
• Are National School Lunch Program

(NSLP) menu items.
• Have a sodium content of 480 mg or
less.
• Do not exceed calorie content of
comparable NSLP entrée items (200-
calorie limit does not apply to
entrees).
1
The Institute of Medicine Committee also developed a list of “Tier 2” foods and
beverages that could be made available to high school students after the end of the
school day. This list is not considered in this study because the Healthy, Hunger-
Free Kids Act addresses foods and beverages available during the school day
only.
2
Combination products must contain a total of one or more servings as packaged of
fruit, vegetables, or whole-grain products per portion.
FINDINGS
Most Competitive Foods and Beverages Selected by Students
Would Not Meet Nutrition Standards
Our analysis of School Nutrition Dietary Assessment III (SNDA-III) data

found that students’ choices were even more skewed toward the less healthy
options than were product offerings. The overwhelming majority—80-90
percent—of competitive foods and beverages selected by students in SY 2004-
05 would not meet criteria based on Institute of Medicine (IOM) Tier 1
standards, depending on the option examined (table 1). The top five
competitive food purchases and their respective shares were: (1) desserts (20.3
percent), (2) sodas and fruit drinks/drinkades (19.5 percent), (3) salty snacks
(12.1 percent), (4) pizza and other entrees (11 percent), and (5) candy (11.1
percent).
The majority of items did not meet the basic criterion of being primarily
one of the major food groups such as fruit, vegetables, whole grains, or low-
fat/nonfat dairy. A larger share of beverages than foods met standards; low-fat
milks and bottled waters made up the majority of these beverages. In the case
of some healthier choices, such as fruit juice, overly large portion sizes were
frequently a problem. Some generally healthy foods, such as yogurts, did not
meet a specific standard such as the standard for sugars. More detailed
information on how competitive foods and beverages compared to criteria
based on IOM recommended standards is provided in Appendix B.
Secondary-Level Students Consumed More Competitive Foods
One-third (33 percent) of elementary-level students consumed competitive

foods on a typical day, whereas more than half (53 percent) of secondary-level
students did. Secondary-level students also consumed twice as many
competitive food items as did elementary-level students—on average, 1.2
items daily compared to 0.6 item. Both differences were statistically
significant (p < 0.001). Thus, older students likely will benefit most from
improvements in dietary intakes at schools that are associated with
establishing nutrition standards for competitive foods.
Competitive Food Revenues Vary across and within School

Grade Levels
Given that most of the competitive items selected by students are low-
nutrient, energy-dense foods, final nutrition standards are likely to exclude
most of the items heavily purchased by students in 2005. What are the
implications for school foodservice revenues?
We expected to see wide variance in revenues obtained from competitive
foods based on students’ selection patterns. À la carte items make up the bulk
of school foodservice competitive food revenues. Although competitive food
sales from vending are common in schools, those revenues are more likely to
go to non-school foodservice sources, with only 20 percent of school
foodservices reporting vending revenues, based on SNDA-III data. Non-
foodservice revenues from competitive foods can go to a range of school-
related groups (see box, p. 10). However, these revenues are not the focus of
this study, except as a local characteristic that may influence the competitive
food revenues of school foodservices, either by competing for student food
dollars or by creating an environment wherein foodservices feel obliged to sell
more competitive foods.
Table 1. Competitive food/beverage items selected by students, school

year 2004-05
Total Percent of Percent of Percent of

number items items items
of items meeting meeting meeting
selected, Option 1 Option 2 Option 3
SY 2005 standards1 standards2 standards3
BEVERAGES (million)
Dairy Whole or 2% milk—flavored 23 -0- -0- -0-
Whole or 2% milk—unflavored 77 -0- -0- -0-
1% of fat free milk—flavored 126 12.6 12.6 12.6
1% of fat free milk—
121 98.3 98.3 98.3
unflavored
Milkshakes and other milk
7 -0- -0- -0-
drinks
Fruit juice 100% fruit juice 164 38.5 55.5 55.5
Sodas, fruit
drinks Carbonated soda (sweetened) 452 -0- -0- -0-
Non-caloric soda (diet) 26 -0- 69.2 69.2
Fruit drinks, fruitades 864 -0- -0- -0-
Bottled water Bottled water 403 93.5 98.0 98.0
Coffee or tea Coffee or tea—unsweetened 42 -0- 50.0 50.0
Total
Percent of Percent of Percent of
number
items items items
of items
BEVERAGES meeting meeting meeting
selected,
Option 1 Option 2 Option 3
SY 2005
standards1 standards2 standards3
(million)
Coffee or tea—sweetened 152 -0- -0- -0-
Beverage total 2,457
Percent of all beverages meeting standard 23.4 26.9 26.9
FOODS
Fruit 143 47 47 47
French fries and similar
Vegetables 148 -0- -0- 7.4
products
All other vegetables 128 31.4 31.4 31.4
Salty snacks Potato chips 225 0.7 0.7 46.2
Popcorn 95 -0- -0- 9.5
Corn, tortilla chips 254 -0- -0- 7.9
Crackers and hard pretzels 257 -0- 0.8 0.8
All except grain-based salty
Breads/Grains 243 -0- 2.1 7.8
snacks
Entrees Pizza or pizza pockets 217 -0- -0- 7.8
All other entrees 540 1.5 4.1 14.8
Ice cream, baked items, all
Desserts 1,399 -0- 0.1 21.5
others
Candy Candy 763 -0- -0- 6.7
Other Soup, not a veg or entree item 16 -0- 18.8 18.8
Food total 4,428
Percent of all foods meeting
2.6 3.2 16.5
standard
Total competitive food/beverage selections 6,885
Percent of total selections meeting IOM
10.0 11.6 20.2
standards
1
Standards matched to Institute of Medicine (IOM) standards (see box, p. 7) as closely
as possible.
2
IOM standards adapted to allow à la carte offerings that were also sold as part of the
reimbursable USDA meal and met IOM fat and total sugar standards, and to allow
a wider range of beverages, i.e. (i) up to 8-oz portion sizes of juice in elementary
schools and 12-oz portion sizes in middle and high schools; and (ii) in high
schools up to 20-oz portion sizes of calorie-free beverages and flavored water; and
(iii) no restrictions on caffeine.
3
IOM standards adapted to allow all à la carte offerings that were also sold as part of
the reimbursable USDA meal and allow a wider range of beverages, i.e., (i) up to
8-oz portion sizes of juice in elementary schools and 12-oz portion sizes in middle
and high schools; and (ii) in high schools up to 20-oz portion sizes of calorie-free
beverages and flavored water; and (iii) no restrictions on caffeine.
Total number of items selected on sample school day, weighted to generate an annual,
national estimate, assuming 180-day school year.
Source: USDA, Economic Research Service analysis, using data from the School
Nutrition Dietary Assessment Study III (SNDA-III), collected in 2004-05.
Non-Foodservice Revenues From Competitive Foods
In many schools, principals, booster clubs, and other non-school

foodservice entities sell competitive foods in vending machines, as
fundraisers, etc. They use revenues to augment school funding, purchase
sports uniforms, fund school trips, or meet other wants and needs.
Revenues obtained from competitive food sales by school entities other
than school foodservices account for only about 5 percent of competitive
food revenues (USDA, FNS, 2013). The legislative requirement for
competitive foods to meet nutrition standards will apply to these groups, in
general, although it does allow for school groups to sell foods that do not
meet standards on a limited number of occasions. This should help affected
school groups to maintain revenues. They may also substitute nonfood
sales and fundraising activities for sales of less healthy foods. Case studies
provide many examples of schools that have used these alternative
strategies to raise funds previously obtained from vending and other
competitive food sales (USDA et al., 2005).
Revenues obtained from competitive food sales differ greatly between

elementary and secondary (middle and high school) levels. Average annual
competitive revenues for elementary schools were about one-sixth those of
middle schools in 2005 and approximately one-ninth those of high schools
(fig. 1). These differences are consistent with the greater purchasing power
and latitude of older students. At the middle and high school levels, the
difference in revenues appears to be attributable to the larger enrollments of
high schools. On a per-student basis, elementary school revenues averaged $16
per student per year in 2005, versus $82 for middle school students and $64
for high school students. This supports our decision to separate elementary and
secondary schools in our analyses.
School foodservice revenues range widely across elementary and
secondary levels. Foodservices in most elementary schools obtain negligible
revenue from competitive foods and beverages. At the median, they received
approximately $2,400 annually (fig. 2). This translates to less than $5 per
student per year. The average foodservice revenue in elementary schools is
dramatically skewed by a minority of schools. At the 75th percentile, school
foodservices obtained almost five times as much revenue as at the median, and
at the 90th percentile they obtained eight times as much as median revenues.
At the secondary level, almost all school foodservices have some

competitive food revenues, but again, the amounts vary considerably. At the
75th percentile, foodservices obtain 2.5 times as much revenue as at the
median, and at the 90th percentile they obtain more than 5 times as much (fig.
2). To some extent, this may be a function of school size, as at the secondary
level enrollments vary considerably. On a per-student basis, the pattern is less
extreme: per-student revenues at the 75th percentile are 2 times as high as at
the median, while revenues at the 90th percentile are 3.7 times as high.
Figure 1. Mean annual school foodservice competitive food revenues.
School Profiles: Characteristics by Food Revenue Quartile
We divided elementary and secondary schools into quartiles based on per-

student foodservice revenues from competitive foods. Within each quartile, we
calculated mean values for each of the characteristics examined
(socioeconomic, geographic, demographic, meal program, nutrition
environment; see Appendix A). The patterns of characteristics associated with
each elementary-school quartile are shown in figures 3A and 4A, and
secondary-level findings are shown in figures 3B and 4B.4 These patterns
allow us to create profiles of schools in which foodservices receive more
revenues from competitive foods.
Nutrition Dietary Assessment Study III (SNDA-II), collected in 2004-2005.
Figure 2. Distribution of annual school foodservice competitive food revenues,
elementary and secondary levels.
Nutrition Dietary Assessment Study III (SNDA-III), collected in 2004-2005. For
complete data table, see Appendix C.
Figure 3A. Socioeconomic and meal program characteristics of elementary schools in

differing foodservice competitive revenue quartiles.
Figure 3B. Socioeconomic and meal program characteristics of secondary schools in

differing foodservice competitive revenue quartiles.
Figure 4A. Nutrition environment characteristics of elementary schools in differing

foodservice competitive revenue quartiles.
Figure 4B. Nutrition environment characteristics of secondary schools in differing

foodservice competitive revenue quartiles.
Whether elementary or secondary, high competitive-revenue schools

shared similar socioeconomic and meal program characteristics. Specifically,
the high-revenue (4th quartile) elementary and secondary schools were:
• More affluent, with none of the high-revenue elementary and

secondary schools located in high-poverty districts. The
overwhelming majority—84 percent of elementary and 81 percent of
secondary schools—were located in low-poverty districts, with the
remainder in medium-poverty districts.
• Serving far fewer students that received free or reduced-price meals.
In the high-revenue quartile elementary schools, 31 percent of
students received free or reduced-price lunch, compared to 63 percent
of students in the lowest revenue quartile. At the secondary level,
high-revenue quartile schools averaged 29 percent of students
receiving free or reduced-price lunch, compared to 42 percent in the
lowest revenue quartile.
• Serving the fewest NSLP meals, with elementary schools in the high-
revenue quartile averaging 63 percent participation, compared to 80
percent in the low-revenue (first) quartile. At the secondary level,
where participation is lower, schools in the high-revenue quartile
averaged 44 percent participation, compared to 64 percent

participation in the lowest revenue quartile.
• Least likely to offer the School Breakfast Program (SBP), with 75
percent of elementary schools in the high-revenue quartile offering the
program compared to 100 percent of the schools in the lowest revenue
quartile. At the secondary level, 75 percent of schools in the high-
revenue quartile offered the SBP, compared to 84 percent of schools
in the lowest revenue quartile.
Findings on ethnicity differed by school level. Elementary schools in the

high-revenue quartile served a smaller percentage of non-White students—26
percent compared to 50 percent in the lowest revenue quartile. At the
secondary level, however, competitive food revenues were unassociated with
race/ethnicity.
High-revenue elementary and secondary schools both charged more for
full-price meals to students. The average meal price for elementary schools in
the high-revenue quartile was $1.56 in 2005, compared to $1.03 for the low-
revenue quartile. For secondary schools in the high-revenue quartile, the
average meal price was $1.89, compared to $1.32 for the low-revenue quartile.
Yet, while they charged higher standard prices than other schools, the revenue
obtained from such meals would still be lower than the free meal
reimbursement. Full-price meals receive a small Federal reimbursement—
$0.21 in the study year. So an elementary school foodservice that charged a
full-price student $1.56 would have had a combined student and Federal
payment of $1.77, and a secondary school charging $1.89 would have a
combined payment of $2.10. Both amounts are lower than the Federal free
meal reimbursement of $2.24 for that year.
Given that higher competitive-revenue schools serve a larger share of full-
price students, they would tend to obtain less revenue from school meals,
possibly leading them to seek additional revenues from competitive foods.
SNDA-III data do not provide school-level information on meal revenues, but
the relationship between competitive food revenues and meal revenues is
explored further in the SFA-level analysis.
School Nutrition Environment Characteristics

Schools in higher and lower competitive revenue quartiles did not differ as
much in nutrition environment characteristics (figs. 4A-4B) as in
socioeconomic and meal program characteristics. Nor did elementary and
secondary levels vary in similar ways. The high-revenue elementary quartile,
compared to the lowest revenue quartile, had higher percentages of schools

that had non-foodservice vending (15 percent versus 4 percent) and fundraisers
selling sweet or salty snacks (43 percent versus 26 percent).
At the secondary level, however, foodservices with the highest
competitive revenues least often co-existed with non-foodservice vending and
fundraisers selling sweet or salty snacks. This lack of internal competition may
have allowed school foodservices to capture student food spending that would
otherwise have gone to these outlets. Vulnerability to outside competition, as
measured by having an open campus, did not seem to follow a consistent
pattern of association with revenue levels. This may be because relatively few
schools allowed students to leave and return during the school day. The pattern
of association between State wellness policies and competitive food revenues
was inconsistent—the low-revenue category had the lowest percentage of
schools covered by a State or district wellness policy, followed by the high-
revenue category (fig. 4B).
In summary, the prototypical high competitive-revenue elementary school
foodservice can be found in a school located in a low-poverty district, serving
primarily nonpoor, White children. It tends to have lower NSLP participation
and is less likely to offer the SBP. It charged higher full prices for NSLP meals
than other districts, but prices were still well below what the foodservice
would have received for a free meal. Competitive foods were more likely to be
available from non-foodservice vendors, perhaps pressuring foodservices to
offer similar items.
At the secondary level, the prototypical high competitive-revenue
foodservice was also found in more affluent districts serving primarily
nonpoor students, had lower NSLP participation, was less likely to offer the
SBP, and charged a higher standard price for a full-price NSLP lunch. Unlike
high-revenue elementary school foodservices, they were less likely to face
competition from nonfoodservice vending, although in all revenue quartiles,
the majority of secondary schools included non-foodservice vending.
School Food Authorities (SFAs) with Higher Shares of Revenue

from Competitive Foods
Using SFA-level data from the School Food Authority Characteristics

Survey (SFACS), we examine competitive food revenues as a share of overall
revenues. At the national level, SFAs averaged 12 percent of revenues from
competitive foods in 2002-03. This is lower than the 16-percent figure
reported in the 2005 School Lunch and Breakfast Cost Study (SLBCS) II. The
difference may be attributable to measure—the SLBCS II included
“miscellaneous” revenues that may have added to the estimate; to sampling
differences; or to a trend to higher competitive revenues across the 2002-05
period. Our analysis found the distribution of competitive food revenue shares
at the SFA level to be less skewed than at the school level. Nevertheless, 54
percent of SFAs had revenues below the mean in 2005 (fig. 5).
The differences in the competitive food share of revenues across SFAs
could be attributed to either higher competitive food revenues, lower USDA
meal revenues, or—as turned out to be the case—both. SFAs with higher
shares of revenues from competitive foods received larger amounts of
competitive food revenues in absolute terms, $1.25 per student per day at the
highest percentile (fig. 6). They also had lower revenues from USDA meals,
both from USDA reimbursements for meals served and from meal payments
made by students.
Source: USDA, Economic Research Service analysis, using data from the School Food
Authority Characteristics Study (SFACS), 2002-03. For complete data table, see
Appendix C.
Figure 5. School Foodservice Authority (SFA) competitive food revenue as percent of

total revenue.
SFA Profiles: Characteristics Associated with Higher Shares of

Revenue from Competitive Foods
To better understand what types of SFAs derived more revenue from

competitive foods, we grouped SFAs into quartiles based on share of revenue
from competitive foods. Analysis of SFA-level socioeconomic characteristics
revealed associations consistent with our school-level analysis. SFAs in the
higher competitive food revenue quartiles were in more affluent districts, with
below-average poverty levels and fewer students receiving free and reduced-
price meals (fig. 7A).
Consistent with meal revenue patterns shown in figure 6, USDA meal
participation was lower in the high-competitive food revenue SFAs (fig. 7B).
Breakfast participation was especially low in the highest competitive revenue
quartile, where breakfasts made up only 13 percent of all USDA meals served
in 2005, compared to 24 percent in the lowest quartile. SFAs in the highest
competitive revenue quartile charged higher average lunch and breakfast
prices to full-price students than did other SFAs, with breakfast charges
averaging $1.01 per meal compared to the national average of $0.94 per meal,
and lunch prices averaging $1.73 per meal compared to a national average of
$1.56. Nevertheless, meal revenues from student payments dropped off as the
share of competitive food revenue increased (fig. 6), probably because of very
low participation.
Appendix C.
Figure 6. Composition of School Foodservice Authority (SFA) revenues in SFAs with

higher shares of revenue from competitive foods.
The SFACS was designed to be representative of FNS regions, allowing

examination of geographic differences. SFAs with higher competitive food
revenues as a share of total revenues were more heavily concentrated in
suburban districts (fig. 8A). They were also much more commonly found in
the Midwest, Northeast, and Mid-Atlantic regions (fig. 8B).
The SFACS data lack information on school-level factors such as presence
of non-foodservice competitive food sales or existence of wellness policies.
The survey does have information on the extent of State financial support to
the school meal programs. SFAs in the highest competitive food revenue
quartile had the lowest level of State support as a percent of revenue—2
percent, compared to 2.7 percent in the lowest quartile and the overall average
of 2.4 percent. State support may be tied to either meal participation or the
financial status of the district. However, these differences are small, and may
be associated with other State differences.
In summary, we find that SFAs with high shares of revenues coming from
competitive food sales tend to serve more affluent, suburban districts; are most
common in the Midwest, Northeast, and Mid-Atlantic regions; and typically
serve more nonpoor students. They serve fewer USDA meals per student
(consistent with the lower participation found at schools with high competitive
food revenues), serve fewer breakfasts as a share of meals, and charge higher
meal prices to full-price students.
Figure 7A. Socioeconomic characteristics of School Foodservice Authorities (SFAs) in

different competitive revenue share quartiles.
Appendix C.
Figure 7B. USDA meal program participation in School Foodservice Authorities

(SFA) in different competitive revenue share quartiles.
Authorities Characteristics Study (SFACS), 2002-03. For complete data table, see
Appendix C.
Figure 8A. Distribution by urbanization of School Foodservice Authorities in different

competitive revenue share quartiles.
Authorities Characteristics Study (SFACS), 2002-03. For complete data table, see
Appendix C. For list of States in each FNS region, see Appendix B.
Figure 8B. Distribution by region of School Foodservice Authorities in different

competitive revenue share quartiles.
LIMITATIONS
School Environment Changes Since 2005
Foremost among this study’s limitations is the fact that these data were
collected some 8 years ago. Since then, State and local competitive food
policies have changed considerably, potentially influencing offerings,
selections, and revenues. By 2010, 39 States had policies concerning the
nutritional quality of competitive foods, although policies varied considerably
and they tended to be weaker in secondary schools. None fully met IOM
standards (CDC, 2012). A recent, nationally representative survey of school
district policies conducted through the Bridging the Gap Program found that a
majority of school districts with policies limiting competitive foods and
beverages were generally not as strict as ones based on the Dietary Guidelines
for Americans would be (Schneider et al., 2012).
Still, these State policies appear to have had some effects on competitive
food offerings. The Kids’ Safe & Healthful Food Project (2012b) found that
many secondary schools reduced availability of less healthy snack foods
between 2002 and 2008, although the decline slowed between 2008 and 2010.
Another study by the Bridging the Gap Program found that availability of
some less healthy items, such as soft drinks, decreased significantly in
secondary schools while healthier beverages like bottled water became
ubiquitous (Johnston et al., 2012). USDA’s SNDA-IV provides updated
information on competitive food offerings for school year 2009-10, although it
lacks the information on student behavior included in SNDA-III (USDA, FNS,
2012). As with SNDA-III, competitive foods and beverages were more limited
at the elementary level. Many healthier items were more widely available in
2009-2010 than they had been in 2005—for example, fresh fruit was available
à la carte in 66.5 percent of high schools in 2009-10, compared to 39 percent
in 2005.
Taken together, these updated findings indicate that many schools have
already expanded healthier offerings and limited at least some less healthy
items. Although most students continue to have access to less healthy
competitive options (Kids Safe & Healthful Foods Project, 2012b; Johnston et
al., 2012, Turner et al., 2010), these changes likely have reduced the challenge
schools face in adapting to updated Federal nutrition standards for competitive
foods.
Other Limitations
The sample is limited to public schools. Private schools also participate in

USDA school meal programs and will need to implement nutrition standards
for competitive foods. However, no comparable data on these schools were
available. Published findings from other sources suggest that private schools
tend to sell a mix of competitive foods and beverages similar to that found in
public schools (Turner et al., 2010). Therefore, the same changes in food
offerings and purchase behavior have likely taken place in private schools that
participate in USDA school meal programs, with similar effects on school
foodservice revenues.
The financial data used in this study are based on questionnaire responses
and may be less accurate than what would be obtained through a more detailed
review of foodservice financial data. We do not have actual prices paid for
specific competitive food and beverage items, requiring us to assume that
competitive items meeting and not meeting proposed Federal standards
contribute equally to revenues on a per-selection basis. It may be possible that
healthier items are priced higher or lower than items not meeting the
standards; if so, that will affect the extent to which implementation of nutrition
standards would influence revenues.
MAKING THE TRANSITION TO HEALTHIER SCHOOL

FOOD CHOICES
Establishing nutrition standards for foods sold at school in competition
with the USDA School Meal Programs should provide nutritional benefits,
especially to secondary-school students who are the largest consumers of
competitive foods. Those benefits should be especially pronounced in the typi-
cally suburban, more affluent SFAs that obtain large shares of revenue from
competitive foods and have relatively low school meal participation.
Nutritional benefits could be either better quality diets, fewer excess calories,
or both.
There may be additional benefits to lowering the profile of competitive
foods in schools. Eliminating less nutritious competitive foods may support
efforts to improve the quality of USDA school meals. Newman et al. (2009)
found NSLP lunches to be lower in fat in schools with no à la carte and
vending. In the competition for student food spending, the absence of
unhealthy alternatives may leave school foodservices more free to offer
healthy meals that meet Federal nutrition standards.
Another potential benefit of restricting competitive foods may be reducing
or eliminating any stigma associated with USDA school meal participation.
Some argue that the presence of competitive foods creates a climate in which
those purchasing competitive foods at lunchtime are perceived as being
nonpoor, while those who eat the school lunch are more likely to be perceived
as low-income, free-lunch recipients (Poppendieck, 2010; Kavanaugh, 2010).
Some students who qualify for free lunch reportedly do not eat it because of
the associated stigma.
For school foodservices concerned about covering their expenses, the
challenge will be to adapt to new standards and develop new strategies for
maintaining revenues in a healthier school nutrition environment. The
challenge is most pronounced to the subset of SFAs receiving a large
proportion of revenues from competitive foods. School foodservices serving
low-income student populations are not at higher financial risk from pending
introduction of nutrition standards. On the contrary, competitive food revenues
are highest in more affluent districts and in schools serving nonpoor children,
where many students are ineligible for free or reduced-price meals.
Higher school foodservice revenues from competitive foods were
associated with lower USDA lunch participation, suggesting that competitive
food revenues may displace meal participation and associated revenue. In
SFAs where competitive food revenues make up a larger share of overall
revenues, foodservice managers may be apprehensive about nutrition-
mandated changes in offerings. Such SFAs will be especially interested in
strategies for maintaining revenues when nutrition standards for competitive
foods are implemented. To offset revenue losses from removal of competitive
foods that fail to meet nutrition standards, school foodservices can (1) seek out
healthier competitive food options to replace those currently sold or (2) re-
emphasize their “core business” by expanding participation in school meals.
For both strategies, appropriate pricing is key. The Healthy, Hunger-Free Kids
Act of 2010 addressed pricing of meals and competitive foods, and new
regulations based on this act may have important effects on revenues obtained
both from USDA school meals and from healthier competitive foods.
Offering Healthier Competitive Foods and Beverages
One strategy for offsetting revenue losses from removal of popular but
unhealthy competitive foods would be to seek out healthier products that meet
nutrition standards. Case studies at the State and local level found that school
foodservices respond to new standards by offering healthier competitive items,
and student behavior adapts to the changed environment.
In Texas, establishment of State nutrition standards in 2004 resulted in
considerable substitution of new or reformulated products for previously
allowed products, and students increasingly bought these products (Cullen and
Watson, 2009). Although this partially compensated for the loss of sales from
less healthy options, overall school food purchases declined 6 percent.
Because we do not have revenue information or specific pricing for each item,
we cannot draw firm conclusions about revenue effects, but assuming each
purchase contributes about the same, the substitution of offerings would
suggest a 6-percent decline in foodservice revenue.
A study of several school districts in California found that, following the
establishment of State nutrition standards in 2007, purchases of compliant
products such as bottled water increased, partially offsetting the drop in
purchases of soda, candy, and other foods not meeting standards. In addition,
meal sales increased. Nevertheless, there was a decline in net revenue,

apparently due to higher food costs (Woodward-Lopez et al., 2010).
Among early adopters of competitive food standards, limited availability
and higher costs of healthier options have been cited as barriers to success
(Woodward-Lopez et al., 2005b). Establishing nationwide standards is likely
to reduce this problem by spurring product development and increasing
demand. In some cases, changes are relatively simple. For example, to meet
IOM standards, juices could be repackaged in smaller containers. In other
cases, reformulation of products may be necessary, but advocacy groups such
as Alliance for a Healthier Generation have already lobbied food manufac-
turers to develop new products for competitive food sales. Examples include
such items as 4-ounce fruit bowls; nonfat, no-sugar- added frozen yogurt; 4-
ounce frozen fruit bars; and reduced-fat/sodium pizza with whole-grain crust
(Alliance for a Healthier Generation, 2010).
Other case studies report changes in competitive food offerings that did
not have significant effects on revenues (Treviño et al., 2012; USDA et al.,
2005). These typically combined changes in competitive food offerings with
other health promotion activities, which may have contributed to their success.
For example, school meal menus and competitive food offerings in 24 middle
schools were modified as part of a health promotion project that also included
physical activity, health education, and social marketing. After 3 years (2006-
09), revenues and expenses of health project schools and matched control
schools were not significantly different (Treviño et al., 2012).
Success in maintaining fiscal stability may hinge on appropriate pricing of
competitive foods. Ironically, the competitive foods that school foodservices
feel compelled to sell may not be helping their overall financial situation. The
SLBCS-II (USDA, FNS, 2008) indicates that in school year 2005-06, school
foodservice competitive food revenues covered, on average, only 71 percent of
costs. Some of the costs associated with competitive food sales, such as labor,
may not be fully considered by school foodservices, leading them to
underestimate the appropriate price for covering costs. Supporting this
possibility, in a study of 344 Minnesota public school districts, Peterson
(2011) found a small but statistically significant negative relationship between
competitive food sales and overall foodservice profit.
To address concerns about underpriced competitive foods, the Healthy,
Hunger-Free Kids Act of 2010 (section 206) requires that beginning in the
2012 school year, competitive foods sold by the school foodservice must
generate revenues appropriate to costs. More appropriate pricing of
competitive foods should result in higher revenues (USDA, 2011b)—and an

improved net financial status of school foodservices.
Expanding School Meal Participation
Expanding meal participation is an especially appealing option for

generating revenues to offset any losses from eliminating sales of less
nutritious competitive foods. USDA meals are designed specifically to meet
nutritional needs of children and reflect the most current nutrition guidance.
Given the relatively low levels of school meal participation in high-
competitive-food-revenue schools and SFAs, there is considerable opportunity
for expanding meal participation. Previous research suggests that if the supply
of competitive foods is removed or greatly reduced, school lunch participation
is likely to increase. An analysis of SNDA-III (USDA, 2007b) found that the
NSLP participation rate was 4.6 percentage points higher in schools that did
not offer competitive food than in those that did. School foodservices with low
initial participation rates—such as schools with higher competitive food
revenues—may raise participation higher than the average rate. However, they
tend to have more students who are not receiving free or reduced-price meals
and may more easily opt to bring food from home. Therefore, expanding meal
participation may be challenging, and may require school foodservices to
intensify their efforts to promote USDA school meal purchases.
Some school foodservices that wanted to de-emphasize competitive foods
as a part of the food environment have launched efforts to improve school
meal participation that result in above-average increases. Kavanaugh (2010)
reports that efforts such as adding new, attractive, healthy items; speeding
service; and making the service area more appealing were successful in
generating large increases in NSLP participation in several school districts that
eliminated or dramatically reduced competitive foods. Given that school meal
participation is particularly low in secondary schools, where competitive food
revenues are highest, efforts to attract secondary students are especially
important. More marketing-style research to identify approaches that appeal to
older students could be useful. For example, a recent study highlighted the
effectiveness of a “healthy express” line that could make a school meal as
quick to pick up as a snack bar item (Hanks et al., 2012).
Breakfasts provided through USDA’s SBP may offer another opportunity
to increase foodservice revenue. However, this strategy can be problematic.
USDA’s School Lunch and Breakfast Cost Study II (SLBCS-II, 2008) reports
that in school year 2005-06, the reported cost of producing reimbursable

breakfasts exceeded reimbursement rates. Other studies have found that
breakfast costs are strongly influenced by participation, which tends to be
much lower than for lunches (Hilleren, 2007; Ollinger et al., 2011a; Ollinger et
al., 2011b). Increasing participation may offer economies of scale, reducing
costs in relationship to revenues. In a pilot study of nutrition improvements in
California schools, offering the SBP in schools not currently participating and
increasing participation where it was already offered were helpful in offsetting
competitive food revenue losses in several schools (Woodward-Lopez et al.,
2005a). This was most effective in schools with more free and reduced-price
students, the group that most typically participates in SBP. In schools with
more full-price students, this strategy may be less successful.
For schools with higher levels of nonpoor students, the success of
strategies that rely on increasing meal participation hinges on the adequacy of
the price charged to full-price students. The SLBC-II found that most schools
underprice the full-price meal charged to their students by 32 percent (USDA,
2008; Kavanaugh, 2010). The Healthy, Hunger-Free Kids Act of 2010
addressed the issue, requiring school foodservices to gradually adjust the full
price upward if the full price is less than the difference between the total
Federal reimbursements for a free lunch and a full-price lunch (or provide
additional non-Federal support for these meals such as State or local funding).
Affected school foodservices are allowed to gradually phase in higher prices,
with meal price increases capped at $0.10 per year. As prices rise to meet
costs, schools with larger percentages of nonpoor students should feel less
pressure to sell competitive foods, assuming they are able to maintain or
increase participation. However, school foodservices may be unable to
maintain or increase participation in the face of required price increases.
Previous research indicates that higher meal prices are associated with lower
participation (USDA, 2007b). School foodservices seeking to move from
reliance on competitive food revenues to increased meal revenues may also
need assistance with marketing efforts to increase the perceived value of the
meal and to instill the willingness to pay a higher price. Alternatively,
advocates may seek to gain State or local support for meals.
CONCLUSION
Most competitive food and beverage items selected by students in 2005
would not meet nutrition standards based on Institute of Medicine guidelines.
Implementation of nutrition standards for competitive foods promises benefits

by improving dietary quality and reducing excess calories from low-nutrient
foods. Although there has been concern that the loss of revenue would hurt
poorer schools most, school foodservices with high competitive food revenues
typically are located in more affluent districts and serve fewer low-income
students receiving free and reduced-price lunch than do schools with low
competitive food revenues.
These school foodservices may particularly benefit from guidance in
making the transition to new competitive food standards. Typically, they tend
to couple higher competitive food revenues with low school meal
participation, so increasing meal participation is a plausible strategy to offset
revenue losses. In addition, these school foodservices could be assisted in
selecting new competitive food products that meet nutrition standards. Such
products are becoming more widely available, and national nutrition standards
for competitive foods will likely spur further product development. Changes in
Federal regulations that should result in more appropriate pricing of full-price
USDA meals and competitive foods could enhance the revenue-generating
effects of these nutrition-based strategies.
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APPENDIX A—CHARACTERISTICS EXAMINED IN SCHOOL-

LEVEL (SNDA) AND SFA-LEVEL (SFACS) ANALYSES
School-Level Analysis (SNDA III data)
Categories Specific Items Information sources
School level Elementary, middle, high National Center for Educational
Statistics (NCES) Common Core
Database (CCD), 2004-05
Socioeconomic Child poverty level of district U.S. Census, 2000
reported on SNDA data file as
falling into one of the following
categories, based on the percentage
of schoolchildren in families with
incomes less than 100 percent of
poverty:
(Continued)

--low (<20 percent)
--medium (20 to <30 percent)
--high (30 percent or more)
Percentage of students receiving National Center for Educational
free or reduced-price meals Statistics (NCES) Common Core
Demographic Percentage of non-White students National Center for Educational
Meal Program Weekly lunch (National School Calculated by Mathematica
Characteristics Lunch Program) participation researchers using data collected
during a target week in which school
menus and meal participation were
recorded by school foodservice man-
agers following standardized
protocols
Average standard price for full- Reported by school foodservice
price lunch managers
School offers USDA School Schools coded as offering SBP if
Breakfast Program (SBP) School Food Authority director
reported that they did and menu
survey reported serving breakfast
menu
School Nutrition Has State, district, or school School principal’s response to
Environment wellness policy question asking whether there was a
wellness policy addressing student
nutrition and physical activity, with
options of (1) school, (2) district, (3)
State, or (0) no policy
Has vending that is not operated by Computed from questionnaire
school foodservice (nonresponse variables indicating that
foodservice vending) there are vending machines present at
the school, but the foodservice does
not receive revenues from them
Has fundraisers selling sweet or Variable created by Mathematica on
salty snacks basis of questionnaire responses
indicating whether the school had any
fundraising activities selling sweet or
salty snacks
Open campus (for secondary Variable created by Mathematica on
schools) basis of questionnaire responses
indicating whether the school had a
policy allowing students to leave and
return to school during the school day
(open campus)

Characteristics Examined in SFA-Level (SFACS) Analysis
Characteristics SFA-level (SFACS) analysis of com- Information sources
petitive food revenue as a share of
total foodservice revenue
School type Elementary, middle, high National Center for Educational
Socioeconomic Poverty level U.S. Census, 2000
--Percent of school-age children in
district in poverty
Shares of students receiving free or Calculated from questionnaire
reduced-price meals data
Geographic USDA Food and Nutrition Service Regions defined by FNS for
region administrative purposes; some of
--Mid-Atlantic (includes Delaware, these regions also included States
District of Columbia, Maryland, New or territories outside of the 48
Jersey, Penn- sylvania, Virginia, West coterminous States, but these
Virginia) were not included in the sampling
--Midwest (includes Illinois, Indiana, frame of this study and are
Michi- gan, Minnesota, Ohio, therefore not listed here.
Wisconsin)
--Mountain (includes Colorado, Iowa,
Kan- sas, Missouri, Montana,
Nebraska, North Dakota, South
Dakota, Utah, Wyoming)
--Northeast (includes Connecticut,
Maine, Massachusetts, New
Hampshire, New York, Rhode Island,
Vermont)
--Southeast (includes Alabama,
Florida, Georgia, Kentucky,
Mississippi, North Carolina, South
Carolina, Tennessee)
--Southwest (includes Arkansas,
Louisiana, New Mexico, Oklahoma,
Texas)
--West (includes Arizona, California,
Idaho, Nevada, Oregon, Washington)
Urbanicity Defined on the basis of the
--Rural Metropolitan Statistical Area
--Suburban (MSA) in which the SFA is
--Urban located
Meal Program Lunch (NSLP) meals per student Questionnaire response provided
Characteristics by SFA
Average price for full-price lunch Questionnaire response provided
by SFA
(Continued)

Breakfast as share of meals Computed on the basis of
questionnaire responses provided
by SFA
State State reimbursement to SFA National Center for Educational
Characteristics Statistics (NCES) Common Core
(CCD), 2002-03
APPENDIX B—CATEGORIZING COMPETITIVE FOOD

SELECTIONS BY ABILITY TO MEET CRITERIA BASED ON
INSTITUTE OF MEDICINE NUTRITION STANDARDS
This analysis was first conducted as part of an effort to assess the possible
effects on students and school foodservices of implementing national nutrition
standards for competitive foods. The analysis examines the extent to which the
mix of competitive foods and beverages selected by students in 2005 would
meet national nutrition standards for competitive foods. In the absence of
established national nutrition standards, we use criteria based on model
nutrition standards developed by the Institute of Medicine (IOM, 2007) as our
guideline (see box, p. 7). Given uncertainty about final standards, we
examined how foods would be categorized under three different options:
a) Standards that matched those described in the box as closely as

possible.
b) Standards that allowed all à la carte offerings that were also sold as
part of the reimbursable USDA meal and met IOM fat and total sugar
standards, and that allowed a wider range of beverages, i.e., (i) up to
8-oz portion sizes of juice in elementary schools and 12-oz portion
sizes in middle and high schools; and (ii) in high schools, up to 20-oz
portion sizes of calorie-free beverages and flavored water; and (iii) no
restrictions on caffeine.
c) Standards that allowed all à la carte offerings that were also sold as
part of the reimbursable USDA meals, and also allowed the beverages
described under option (b).
Data and Methods
Our data source is the School Nutrition Dietary Assessment Study III
(SNDA-III), conducted in the 2004-05 school year. This provides the most
recent nationally representative data on foods consumed at school, their
sources, and their nutrient composition. SNDA-III was conducted for the Food
and Nutrition Service of the U.S. Department of Agriculture by Mathematica
Policy Research, Inc. (Mathematica). Its staff collected information on all
foods selected and consumed by students within a given 24-hour period that
included a school day. Mathematica researchers classified foods obtained at
school as being part of the USDA school meal or as competitive items using
methods described by Fox et al. (2009). Survey weights that could be used to
generate nationally representative findings were developed by Mathematica
and included in the public-access data file used in this analysis.
SNDA-III does not identify foods by purchase occasion, but rather by
eating occasion. Therefore, we assessed frequency of item selection as a proxy
for purchase frequency. For each item selected, we compared its nutritional
composition to standards based on the three options described above. Each
item was identified as meeting or not meeting standards on this basis of its
specific composition. As a result, within a given type of food or beverage,
some might meet nutrition standards, others not. For example, some low-fat
flavored milks might not meet the standard for sugar content, while others
made with less sugar might meet the sugar content.
After each item was classified as meeting or not meeting the standards,
items were grouped by major beverage or food categories. The total number of
selections of each item was generated using SNDA-III data, which were
annualized assuming a 180-day school year. Results were weighted to provide
nationally representative findings.
Findings
Tables B1-B6 provide detailed information on beverages and foods

selected by students and the share of selections that met standards, as well as
the specific standards not met. More beverage than food items met standards—
23-27 percent, depending on the option examined. Low-fat milk, juice, and
especially bottled water were the beverages that most often met standards.
However, even within these categories, not all choices completely met the
standards. The majority of flavored lowfat milks exceeded the sugars standard.
Many fruit juice selections (our proxy for purchase size) were of overlarge
portion size, even under options that allowed larger sizes. Even some bottled
waters did not meet criteria regarding flavors and sweeteners.
Under every option, a smaller proportion of foods than beverages selected
by students met the Tier 1 standards. Fewer than 3 percent met all IOM
standards, but allowing any NSLP item to be sold à la carte raised the share of
saleable items to 16.5 percent. Generally, competitive foods are criticized as
being high in fat, sodium, or sugars. Large numbers of food items failed to
meet standards for those nutrients, but the biggest single reason for not
meeting standards was the failure to provide meaningful amounts of healthful,
underconsumed food groups like low-fat dairy, whole grains, vegetables,
fruits. Again, there were some categories in which some items met standards,
and others did not. For example, some potato chips met all standards, perhaps
because they were baked rather than fried, made with less sodium, and/or sold
in smaller packages. Because updated USDA school meal standards have
likely resulted in items that are also sold as part of the NSLP being lower in
fat, sodium, and sugars, the nutritional quality of à la carte items also sold as
part of the NSLP has likely improved since 2005.
Limitations
The model IOM standards provided the guiding principles for our
analysis. However, using them to classify food items required us to make some
operational decisions, as described in the footnotes to our tables. For example,
portion size was an important criterion for fruit juices, but we did not have
direct information on purchase size. Instead we estimate purchase size based
on amount consumed, and we also based our cutoffs on slightly larger amounts
consumed (e.g., 4.5 oz. rather than 4 oz. of juice) to allow for reporting error.
Since these data were collected in 2005, some States and/or school
districts have developed policies limiting sales of less nutritious competitive
foods and beverages. Therefore, the composition of competitive foods may
have changed since 2005. However, we lack more recent national data with the
level of detail necessary for these estimates. Given changes in school policies,
these should be considered upper-bound estimates of the shares of competitive
food and beverage selections that would not meet IOM model standards.
Table B1. Competitive beverage items selected by students - Option 1; Tier One Institute of Medicine (IOM)
Standards
Note: Total number of items selected on sample school day, weighted to generate an annual, national estimate. Selections are considered
proxies for purchases.
Source: Economic Research Service analysis of School Nutrition Dietary Assessment Study-III 2005 student recall dietary data.
Table B2. Competitive food items selected by students - Option 1; Tier 1 Institute of Medicine (IOM) Standards
Note: Total number of items selected on sample school day, by commodity-based groups, weighted to generate an annual, national
estimate. Selections are considered proxies for purchases.
Source: Economic Research Service analysis of School Nutrition Dietary Assessment Study-III 2005 student recall dietary data.
Appendix Table B3. Competitive beverage items selected by students - Option 2, modified Institute of Medicine
(IOM) standards
Note: Total number of items selected on sample school day, weighted to generate an annual, national estimate. Selections are considered
proxies for purchases.
Source: Economic Research Service analysis of School Nutrition Dietary Assessment-III 2005 student recall dietary data.
Appendix Table B4. Competitive food items selected by students - Option 2, modified Institute of Medicine (IOM)
standards
Appendix Table B4. (Continued)
estimate Selections are considered proxies for purchases.
Table B5. Competitive beverage items selected by students - Option 3, Modified Institute of Medicine (IOM)
standards
estimate.
Selections are considered proxies for purchases.
Table B6. Competitive food items selected bystudents - Option 3, Modified Institute of Medicine (IOM) standards
estimate Selections are considered proxies for purchases.
Most importantly, these are model standards developed by an independent

organization, not actual national nutrition standards. The Food and Nutrition
Service (FNS) of USDA has not yet issued final standards; those standards
may be quite different from any of the options examined here. Therefore,
findings provide only a general guide to how food items might be affected by
national nutrition standards. Nevertheless, these data provide insights into how
products commonly selected by U.S. students compare to model nutrition
standards and suggest potential areas for improvement, for example by
decreasing portion sizes of some items, such as juice, or developing lower-
sugar versions of some items, such as yogurts.
APPENDIX C. DATA TABLES FOR FIGURES 2-6

Table C.1. Distribution of annual school foodservice competitive food
revenues, at elementary and secondary levels (data for Figure 2)
Elementary school competitive Secondary school competitive food

Percentile
food revenues revenues
1 $0 $0
10 $0 $0
25 $18 $3,928
50 $2,395 $27,803
75 $11,394 $69,339
90 $19,048 $148,275
95 $32,975 $203,812
99 $81,594 $414,317
Table C.2. Characteristics of elementary schools in differing school

foodservice competitive food revenue quartiles
(data for Figures 3A and 4A)
Elementary schools
School foodservice competitive food revenue quartiles (school
foodservice competitive food revenues per student per year)
>50th -
>25th - <=50th <=75th %tile >75th
Overall <=25th %tile (>0 - >$4.82 - %tile
mean %tile 0 <=$4.82) <=23.41 >$23.34
% Low poverty (More
64.5% 37.8% 60.8% 60.9% 83.9%
affluent districts)
% Medium poverty 28.6% 39.9% 37.8% 29.8% 16.1%
Elementary schools
>50th -
>25th - <=50th <=75th %tile >75th
Overall <=25th %tile (>0 - >$4.82 - %tile
mean %tile 0 <=$4.82) <=23.41 >$23.34
% High poverty 7.0% 22.3% 1.4% 9.5% 0.0%
% Students receiving
free/reduced price meals 46.2% 63.1% 50.5% 52.9% 30.6%
% Non-white students 35.8% 50.2% 40.1% 38.7% 25.6%
Weekly lunch participation 69.8% 80.1% 70.3% 69.9% 63.1%
Average price of full-price
$1.44 $1.03 $1.50 $1.49 $1.56
meal
Offer school breakfast
79.3% 100.0% 67.2% 80.3% 75.0%
program
Have non-foodservice
11.3% 4.3% 9.7% 17.0% 14.7%
vending
Have fundraisers selling
sweet or salty snacks 36.9% 25.6% 39.6% 36.0% 43.4%
Have State or District level
34.4% 41.6% 29.0% 38.0% 37.1%
wellness policy
Nutrition Dietary Assessment Study III (SNDA-III), collected in 2004-2005
Table C.3. Characteristics of secondary schools in differing

schoolfoodservice competitive food revenue quartiles
(data for Figures 3B and 4B)
Secondary schools
>25th- >50th -
<=50th <=75th
<=25th % tile %tile
Overall %tile >$5.79- >$46.91- >75th %
mean <=$5.79 <=$46.91 <=$99.21 >$99.21
% Low poverty (More affluent
68.2% 56.2% 63.1% 70.5% 80.9%
districts)
% Medium poverty 26.0% 32.1% 32.8% 24.2% 19.1%
% High poverty 5.9% 11.7% 4.1% 5.2% 0.0%
% Students receiving
free/reduced price meals 39.3% 42.4% 46.1% 39.2% 29.0%
% Non-white students 30.7% 29.4% 28.4% 37.8% 27.8%
Weekly lunch participation 53.5% 64.3% 56.4% 48.3% 44.3%
Average price of full-price meal $1.62 $1.32 $1.66 $1.65 $1.89
Offer school breakfast program 83.0% 83.9% 85.3% 85.1% 75.1%
Have non-foodservice vending 69.4% 64.5% 69.0% 77.8% 60.2%
Table C.3. (Continued)
Secondary schools
>25th- >50th -
<=50th <=75th
<=25th % tile %tile
Overall %tile >$5.79- >$46.91- >75th %
mean <=$5.79 <=$46.91 <=$99.21 >$99.21
Have open campus 15.7% 22.0% 13.4% 23.7% 6.5%
Have fundraisers selling sweet
or salty snacks 52.3% 50.7% 56.9% 58.8% 35.0%
Have State or District level
24.1% 12.5% 40.1% 28.5% 18.1%
wellness policy
Table C.4. School Foodservice Authority (SFA) competitive food revenue

as percent of total revenue (data for Figure 5)
Percentile of SFAs Competitive food revenue as a percent of total SFA revenue

0 0%
10 0%
20 0%
30 3%
40 6%
50 11%
60 15%
70 21%
80 27%
90 36%
95 44%
99 70%
Authorities Characteristics Study (SFACS), 2002-03.
Table C.5. Composition of School Foodservice Authority revenues in

SFAs with higher shares of revenue from competitive foods
(data for Figure 6)
Composition of SFA Revenues on a Per-Student, Per-Day Basis

Percentiles of USDA meal Student payments Competitive food
SFAs reimbursements for USDA meals sale revenues
0 $1.15 $0.38 $0.00
20 $1.11 $0.64 $0.01
Composition of SFA Revenues on a Per-Student, Per-Day Basis

Percentiles of USDA meal Student payments Competitive food
SFAs reimbursements for USDA meals sale revenues
30 $1.40 $0.46 $0.06
40 $1.36 $0.54 $0.13
50 $1.05 $0.54 $0.20
60 $0.71 $0.56 $0.25
70 $0.54 $0.64 $0.34
80 $0.58 $0.47 $0.42
90 $0.50 $0.45 $0.58
95 $0.33 $0.53 $0.78
99 $0.20 $0.30 $1.25
Table C.6. Characteristics of School Foodservice Authorities in differing

quartiles defined by share of revenues from competitive foods
School foodservice competitive food revenue quartiles

National
mean 1 2 3 4
>25th- >50th -
<=25th <=50th % <=75th >75th
%tile tile %tile %
School Type
Percent Elementary Schools 63.4 62.2 64.5 63.6 63.0
Percent Middle Schools 17.6 16.7 16.9 18.3 18.5
Percent High Schools 19.0 21.1 18.5 18.1 18.5
Socioeconomic
Average Poverty Level of District 15.4 18.2 17.5 13.5 9.5
Percent Students Receiving Free
31.2 38.1 34.8 27.8 17.4
Meals
Percent Students Receiving
9.3 10.5 10 9.2 6.4
Reduced-Price Meals
Geographic
Percent Rural 50.7 56 63.8 49.0 26.0
Percent Suburban 41 31.3 30.3 44.1 69.4
Percent Urban 8.3 12.7 5.9 6.9 4.6
Percent Mid-Atlantic 10.0 8.6 5.6 10.0 18.5
Percent Midwest 24.6 17.9 19.8 36.1 30.8
Percent Mountain 16.0 20.0 24.2 9.2 4.9
Percent Northeast 11.7 4.2 9.3 14 26.6
Percent Southeast 8.3 2.7 14.9 14.3 3.8
Percent Southwest 15.3 23.7 15.9 9.2 5.4
Percent West 14.1 22.9 10.3 7.2 10
State
State reimbursement as percent of
2.4 2.7 2.5 2.4 2.0
revenue
Table C.6. (Continued)
School foodservice competitive food revenue quartiles

National
mean 1 2 3 4
>25th- >50th -
<=25th <=50th % <=75th >75th
%tile tile %tile %
Meal Characteristics
Average breakfast price 0.94 0.94 0.89 0.9 1.01
Breakfasts as percent of USDA
20.4 24.0 21.8 18.6 13.2
meals
Average lunch price 1.56 1.56 1.43 1.55 1.73
National School Lunch Program
lunches per student (annual) 113.9 115.0 124.9 122.1 88.9
USDA breakfasts per student
34.0 44.6 37.9 27.5 16.6
(annual)
End Notes
1
USDA recently released findings from its School Nutrition Dietary Assessment IV (SNDA-IV),
including updated information on competitive food offerings in school year 2009-10.
Because SNDA-IV did not have data on student food selections, we did not update our
analysis. However, we consider how findings from SNDA-IV add to the interpretation of
our findings.
2
The Healthy, Hunger-Free Kids Act of 2010 added requirements for monitoring compliance
with local wellness policies and making findings publicly available.
3
A small number of school foodservices may also have received revenues from school stores and
snack bars but these revenues were not included because of problems identifying either (a)
what share of revenues were received by school foodservices; (b) for stores, what share of
revenues was attributable to food; or (c) for snack bars, whether school foodservice
revenues were not already included in à la carte totals. Revenue attributable to snack bars
and school stores was quite small compared to à la carte and vending.
4
Complete data for all elementary and secondary quartiles can be found in Appendix C.
Chapter 2
SCHOOL MEAL PROGRAMS:

COMPETITIVE FOODS ARE WIDELY
AVAILABLE AND GENERATE SUBSTANTIAL
REVENUES FOR SCHOOLS*
United States Government Accountability Office
WHY GAO DID THIS STUDY

Recent increases in child obesity have sparked concerns about competitive
foods—foods sold to students at school that are not part of federally
reimbursable school meals. The nutritional value of these foods is largely
unregulated, and students can often purchase these foods in addition to or
instead of school meals. In our April 2004 report on competitive foods (GAO-
04-673), we reported that several states had enacted competitive food policies
that were more restrictive than federal regulations. However, these policies
differed widely in the type and extent of restrictions. In addition, it was
unclear how and to what extent states were monitoring compliance with these
policies. GAO was also asked to provide a national picture of competitive
foods in schools, as well as strategies that districts and schools themselves are
taking to limit the availability of less nutritious competitive foods. This report
*
This is an edited, reformatted and augmented version of United States Government
Accountability Office, Publication No. GAO-05-563, dated August 2005.
60 United States Government Accountability Office
provides information from two nationally representative surveys about the

prevalence of competitive foods in schools, competitive foods restrictions and
groups involved in their sale, and the amounts and uses of revenue generated
from the sale of competitive foods. It also provides information about
strategies schools have used to limit the availability of less nutritious
competitive foods, based on visits to a total of six school districts in
California, Connecticut, Mississippi, Missouri, and South Carolina.
WHAT GAO FOUND

Nearly 9 out of 10 schools sold competitive foods to students in school
year 2003-2004, and the availability of competitive foods sold in middle
schools and through a la carte lines has increased over the last 5 years. Schools
often sold these foods in or near the cafeteria and during lunch, and the
competitive foods available ranged from nutritious items such as fruit and milk
to less nutritious items such as soda and candy. High and middle schools were
more likely to sell competitive foods than elementary schools.
Many different people made decisions about competitive food sales, but
no one person commonly had responsibility for all sales in a school. In a
majority of schools, district officials made competitive food policies, while
school food authority directors and principals made decisions about specific
sales. Other groups, such as student clubs and booster groups, also made
competitive food decisions through their direct involvement in sales.
Many schools, particularly high schools and middle schools, generated
substantial revenues through competitive food sales in 2003-2004.
Specifically, the nearly 30 percent of high schools generating the most revenue
from these sales raised more than $125,000 per school. Food services,
responsible for providing federal school meals, generally spent the revenue
they generated through a la carte sales on food service operations. Other
school groups often used revenues for student activities.
The six school districts visited all recently took steps to substitute healthy
items for less nutritious competitive foods. In each district, committed
individuals took actions to initiate and lead change while also involving those
affected. However, districts faced several barriers to change, including
opposition due to concerns about revenue losses. In the districts visited, the
effects of changes on revenues were often unclear because of limited data.
School Meal Programs 61
Source: GAO.
A Majority of Schools Sell Competitive Foods to Students through Vending Machines.
ABBREVIATIONS
CCD Common Core of Data
CDC Centers for Disease Control and Prevention
FMNV foods of minimal nutritional value
FNS Food and Nutrition Service
HHS Department of Health and Human Services
NSLP National School Lunch Program
SFA school food authority
USDA U.S. Department of Agriculture
WIC Special Supplemental Nutrition Program for Women,
Infants, and Children
August 8, 2005
The Honorable Tom Harkin

Ranking Member
Committee on Agriculture, Nutrition,
and Forestry United States Senate
The Honorable Patrick J. Leahy

Ranking Member
Subcommittee on Research, Nutrition, and General Legislation
Committee on Agriculture, Nutrition, and Forestry
United States Senate
The Honorable George Miller

Ranking Member
Committee on Education and the Workforce
House of Representatives
The Honorable Lynn Woolsey

Ranking Member
Subcommittee on Education Reform
Committee on Education and the Workforce
House of Representatives
Increasing child obesity rates have recently focused attention on children’s

health and nutrition and have raised concerns about foods available in schools
that compete nutritionally and financially with federally regulated school meal
programs. The number of children who are overweight has more than doubled,
and the number of adolescents who are overweight has more than tripled since
1980, according to the U.S. Centers for Disease Control and Prevention
(CDC). These changes are related, in part, to poor nutrition. According to U.S.
Department of Agriculture (USDA) data, more than 60 percent of young
people eat too much fat and less than 20 percent of the recommended daily
servings of fruits and vegetables. In addition to having negative health
outcomes, children with poor nutrition may have a harder time concentrating
and succeeding in school than other children. The Surgeon General’s 2001 call
to action identified schools as one of the key settings for public health
strategies to address child nutrition. Since children spend a large portion of
their day in school, providing them with healthful food options throughout the
school day can be an important step toward good child nutrition.
The key school meal programs, the National School Lunch Program and
the School Breakfast Program, provide millions of children with nutritious
meals each school day. USDA’s Food and Nutrition Service administers these
programs through local school food authorities (SFA) and subsidizes the meals
served in local schools as long as meals meet certain nutritional guidelines.
However, other foods not provided through these programs, typically referred
to as competitive foods, are often available to children at school. Competitive
food sales can take place at a variety of venues in schools, including vending
machines, school stores, and a la carte lines in the cafeteria, through which the
SFA sells individually priced food and beverage items. Federal restrictions
concerned with the nutritional value of competitive foods are limited.
Specifically, federal regulations require that one segment of competitive foods,
defined as foods of minimal nutritional value, not be sold to students during
the breakfast and lunch periods in food service areas.
In recent years, federal, state, and local governments have increasingly
focused on the role that competitive foods play in children’s diets. In our April
2004 report on competitive foods,1 we reported that increasing numbers of
state legislatures have enacted and proposed legislation to restrict the
availability of competitive foods in schools. In addition, school districts and
schools themselves are taking steps to limit the availability of competitive
foods.
Because of your interest in further understanding issues related to
competitive foods in schools, you asked us to answer the following questions:
(1) How prevalent is the sale of competitive foods in schools across the
country, and has this prevalence changed over time? (2) Who makes decisions
about competitive food sales in schools? (3) What amount of revenue is
generated from the sale of competitive foods, and for what purposes is the
revenue used? (4) What strategies have schools used to limit the availability of
less nutritious competitive foods, what obstacles did they face, and how have
these strategies affected sales revenue?
To answer your first three questions, we obtained information through two
Web surveys, one of school principals and the other of district-level SFA
directors. To conduct our surveys, we selected a stratified random sample from
the 80,000 public schools nationwide that participate in the National School
Lunch Program, which allowed us to provide national estimates based on
school level. The surveys were administered between October 19, 2004, and
February 11, 2005, with 65 percent of principals and 70 percent of SFA
directors responding.2 The surveys asked respondents about conditions in their

schools during specific school years, primarily 2003-2004, and therefore, all
years cited refer to school years. In addition, all estimates presented from the
surveys have margins of error of plus or minus 15 percent or less, unless
otherwise noted. To answer the fourth question, we conducted site visits to 6
school districts in California (Oakland), Connecticut (New Haven),
Mississippi (McComb), Missouri (Independence and Fort Osage), and South
Carolina (Richland One), including visits to a total of 10 schools. Our site visit
localities were selected from a group of approximately 100 districts and
schools recognized as making efforts to limit access to less nutritious
competitive foods. The 6 districts visited were also selected because it
appeared that they used different strategies to restrict competitive foods, and
when viewed as a group, they provided variation across characteristics such as
geographic location, district size, and socioeconomic status. See appendix I for
detailed information on our surveys, sampling strategy, and site visits.
We conducted our work from May 2004 through July 2005 in accordance
with generally accepted government auditing standards.
RESULTS IN BRIEF
Almost all schools sold competitive foods to students in school year 2003-
2004, and over the last 5 years, the availability of competitive foods has
increased both in middle schools and in a la carte lines in many schools. We
estimate that nearly 9 out of 10 schools offered competitive foods through one
or more of the following venues in 2003-2004: a la carte cafeteria lines,
vending machines, and school stores. While competitive foods were
commonly sold in schools of all levels, high schools and middle schools were
more likely to sell these foods than elementary schools. For example, vending
machines were available to students in almost all high schools and middle
schools but in less than half of elementary schools. Schools often sold
competitive foods in or near the cafeteria and during lunchtime, allowing
students to purchase these foods as their lunch or to supplement their lunch.
The competitive foods available ranged from nutritious items such as fruit and
milk to less nutritious items such as soda and candy, with nutritious foods
more frequently available through a la carte lines than through vending
machines or school stores. Between 1998-1999 and 2003-2004, the availability
of competitive foods increased in middle schools, and the volume and variety
of a la carte foods sold increased in many schools.
Many people, including district and school officials as well as members of

groups involved in sales at schools, made decisions about competitive foods,
but no one person commonly had responsibility for all competitive food sales
at the school level. The decisions ranged from broad policies about the school
nutrition environment to decisions about which foods to sell at a specific
venue or event. According to school principals, an estimated 60 percent of
schools had written policies in place in school year 2003-2004 that restricted
competitive food sales to students, and in a majority of those schools the
policies were set at the district level, often by superintendents and school
boards. Regarding competitive food sales in schools, district SFA directors
were commonly involved in policy decisions related to a la carte sales, while
school principals often had final approval over other competitive food sales,
such as items sold through vending machines. In addition to SFA directors and
school principals, many other groups such as teachers, student clubs, parent-
teacher associations, and booster groups were involved in selling competitive
foods in schools. These groups therefore often made decisions concerning the
types of food to sell to students and when to make such food available. The
number and variety of groups involved in these sales typically increased as the
school level increased.
Many schools raised a substantial amount of revenue through competitive
food sales in school year 2003-2004 and used this revenue to support food
service operations and student activities. High schools and middle schools
generally raised more revenue from competitive food sales than elementary
schools, reflecting the greater availability of competitive foods in high and
middle schools. According to our survey, the nearly 30 percent of high schools
generating the most revenue from competitive food sales raised more than
$125,000 per school in 2003-2004. Across all competitive food sales, food
services generated more revenue than other school groups, largely through a la
carte sales, and they generally used this revenue to support overall food
service operations. Other school groups commonly used their revenues to
support student activities, and the most frequent uses were student field trips,
school assemblies and programs, and athletic equipment and facilities.
The six school districts we visited all recently took steps to substitute
healthy competitive foods for less nutritious fare while overcoming obstacles
to these changes, and the effects of these changes on sales revenues were often
unclear because of limited data. Specifically, many of the schools we visited
increased the availability of healthy items, including low-fat and low-sugar
foods and beverages, while they decreased the availability of less nutritious
foods, such as deep-fried French fries, candy, and soda. Further, although
different districts used different approaches and achieved different outcomes,

district and school officials identified several factors that consistently
facilitated change and several that hindered it. For example, in all of the
districts we visited, motivated individuals took action to initiate and lead the
process of change while obtaining support from those affected in the district,
schools, and community. However, districts noted that they also faced many
barriers to implementing changes, such as opposition due to concerns about
potential revenue losses. Regarding the effect of changes on sales revenues,
none of the districts we visited had clear and reliable data concerning the
impact of competitive food changes on sales revenues. From the limited data
that were available, it appeared that changes had varied effects on revenues
across districts. Related to this, while a few districts anticipated and planned
for the effects of changes on sales revenues, most had not. Consequently,
many officials expressed strong concerns about potential revenue losses
because competitive food revenues have provided them with a valued source
of funding.
BACKGROUND
Competitive foods in schools are those foods sold to students during the
school day that are not part of the federal meal programs. These federal
programs, the National School Lunch Program (NSLP) and the School
Breakfast Program, subsidize public school meals and regulate their nutritional
content. Competitive foods, however, are only minimally regulated at the
federal level. They are typically sold a la carte in the cafeteria, and through
vending machines and school stores.
NSLP and School Breakfast Program
The two largest federal school meal programs, the NSLP and the School
Breakfast Program, aim to address problems of hunger, food insecurity, and
poor nutrition by providing nutritious meals to children in schools. The NSLP,
established in 1946, provides nutritionally balanced low-cost or free lunches in
participating schools to more than 28 million children each school day, as well
as reimbursement for snacks served to those through age 18 in after-school
educational and enrichment programs. Similarly, the School Breakfast
Program, permanently established in 1975, provides free or reduced price
breakfasts to more than 8 million schoolchildren daily.3 At the federal level,

these programs are administered by USDA’s Food and Nutrition Service
(FNS). As part of its strategic goal to improve the nation’s nutrition and
health, the department has laid out plans to increase access to, and utilization
of, these school meal programs.
In fiscal year 2004, the federal government spent over $8 billion on the
NSLP and the School Breakfast Program. FNS provides reimbursement in the
form of cash subsidies and donated commodities based on the number of
lunches and breakfasts served that meet certain federal requirements. The
meals must adhere to the Dietary Guidelines for Americans, which include
limits on total fat and saturated fat and call for diets moderate in sodium.4 The
meals must also meet standards for the recommended daily allowances of
calories, as well as nutrients such as protein, calcium, iron, and vitamins A and
C. Compliance with the standards is determined by averaging the nutritional
content of the meals offered over a school week. USDA reimburses states,
usually through the state departments of education, which in turn reimburse
local SFAs that operate the programs in one or more schools.
SFAs function as the governing entities responsible for the local
administration of the federal meals programs. They are often, but not always,
responsible for school meals in an entire school district. SFAs have some
flexibility in operating their school meal programs. For example, 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 then distribute food to satellite
schools. In addition, SFAs may select among different menu-planning
approaches to comply with the federal nutritional requirements.
SFAs receive a significant portion of their funding from federal
reimbursements that are based on the number of meals served to students in
their schools. In addition, SFAs also receive some funding from states for
program operations, and they may generate revenues by selling competitive
foods or by offering fee-based catering services. Further, SFAs are permitted
to combine costs and revenues for reimbursable meals and nonreimbursable
offerings, such as competitive foods, as long as they maintain their nonprofit
status. Therefore, if revenues from reimbursable meals are less than the costs
of producing these meals, SFAs may use competitive food revenues to support
the cost of reimbursable meals. Likewise, if revenues from reimbursable meals
are more than the costs of producing these meals, SFAs may use these funds to
support competitive food sales.
Minimal Federal Restriction of Competitive Foods
Competitive foods are those foods sold in schools, during the school day,
that are not part of the federal school meal programs—that is, they compete
with the nutritionally regulated school meal programs. These foods can range
from candy and soda to pizza and popcorn to apples and milk and are typically
available in cafeteria a la carte lines, vending machines, and school stores.
Unlike federally subsidized school meals, the sale and nutritional content
of competitive foods are largely unregulated by the federal government.
Federal regulations prohibit the sale of certain competitive foods, known as
foods of minimal nutritional value (FMNV),5 during meal periods in school
cafeterias and other food service areas. FMNV, as defined by USDA, include
soda, chewing gum, and hard candy, for example (see fig. 1). Other than this
restriction, federal regulations do not prohibit or limit the sale of any other
competitive foods anywhere on school grounds at any time.6 In contrast, from
1980 to 1983, federal regulations prohibited the sale of FMNV anywhere in
the school from the beginning of the school day until the last meal period. 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 this regulation and
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.
According to federal regulations, states and SFAs may impose further
restrictions on all foods sold at any time throughout their schools. As of April
2005, 28 states have made efforts to restrict the sale of competitive foods
beyond USDA regulations (see fig. 2). Five state policies do not restrict
particular food items, but instead typically address the competitive food
environment more broadly. For example, some of these states have created
committees to develop policies concerning competitive foods in schools or
have encouraged schools to find ways to improve their competitive food
environments. The remaining 23 of these state policies place some form of
specific restrictions on competitive foods, though they differ in the type and
extent of restrictions. 7 The majority of these policies restrict some, but not all,
competitive foods and restrict foods only at times associated with school meal
periods, rather than during the entire school day.8
Source: GAO, clip art source: Art Explosion.
Figure 1. Categories and Sources of Competitive Foods in Schools.
Recent Federal Initiatives to Promote Better Nutrition in Schools
The federal government has an interest in improving child nutrition in

order to promote the health and wellness of the nation’s children. Moreover,
the current child obesity trend poses public health risks because of the
relationship of obesity to serious illnesses, such as type 2 diabetes and
hypertension. These illnesses can result in substantial longterm costs to
society. In response, USDA has recently developed initiatives to support
school efforts to provide a healthy nutrition environment, including
competitive food sales. Beginning in 1995, USDA introduced the School
Meals Initiative for Healthy Children in an effort to improve the nutritional
quality of meals served through the NSLP and the School Breakfast Program.
Source: GAO.
Figure 2. States That Have Made Efforts to Restrict Competitive Foods in Schools beyond USDA Regulations, as of April 2005.
That same year, in order to assist with implementation of the School

Meals Initiative, USDA launched Team Nutrition to focus on schools and
promote the nutritional health of the nation’s children. Team Nutrition
provides schools with nutrition education materials for children and families,
technical assistance materials for school food services, and materials to build
school and community support for healthy eating and physical activity.9 Since
1995, USDA has also created additional resources to help schools improve
student nutrition, address competitive foods, and foster long-term health,
sometimes in collaboration with other federal agencies (see table 1).10
Table 1. Select USDA Initiatives That Promote Child Nutrition and

Address the Competitive Food Environment
Initiative Description
Toolkit that focuses on improving the school
Changing the Scene–Improving
nutrition environment and serves as a guide to
the School Nutrition Environment
local action, developed with input from 16
(2000)
education, nutrition, and health organizations
Toolkit for school food service professionals
Fruits and Vegetables Galore
that contains tips on promoting fruits and
(2004)
vegetables to children
Effort to recognize schools that have met higher
standards for nutrition and physical activity
HealthierUS School Challenge
than those required by the federal government,
(2004)
and to encourage other schools to achieve such
results
Report that shares stories from 32 schools and
school districts that have made innovative
changes to improve the nutritional quality of all
Making it Happen! School
foods and beverages sold on school campuses,
Nutrition Success Stories (2005)
including competitive foods, developed in
collaboration with CDC and supported by the
Department of Education
Source: GAO.
The Department of Health and Human Services (HHS) has also focused
on the school nutrition environment through various initiatives by CDC. These
include
• an eight-component coordinated health model for schools that

includes school nutrition services as one component, and
• a School Health Index designed to help schools assess their

environments and improve the effectiveness of their health and safety
policies and programs.11
In addition to these efforts to support a healthy school nutrition

environment, the National Academy of Sciences’ Institute of Medicine
recently released a broad-based report on preventing childhood obesity.
Among other things, the institute recommended that the current federal
funding structure of school meals and the policies and practices of selling
competitive foods in schools be examined for improvements that would
encourage students to consume nutritious foods and beverages, and that
nutritional standards be developed and implemented for all competitive foods
sold or served in schools.
On the Horizon: School Wellness Policies and Research on

Nutritional Standards
The Child Nutrition and WIC Reauthorization Act of 2004 requires school
districts that participate in the federal meal programs to establish local
wellness policies by the first day of the 2006-2007 school year. 12 Congress
added this requirement, in part, in order to promote nutrition and address child
obesity by encouraging localities to provide healthy school environments.
These policies must include nutrition guidelines for all foods available on each
school campus during the school day and goals for nutrition education and
physical activity, as well as establish a plan for measuring implementation of
the local wellness policy. Further, the local wellness policies must be
developed in collaboration with the community—including a combination of
school officials, parents, students, and the public. The act also requires that
USDA, HHS—through CDC—and the Department of Education provide
technical assistance to districts regarding wellness policies. In addition, in
order to assist schools in setting appropriate nutrition standards for foods
available in schools, Congress—through the Conference Report of the
Consolidated Appropriations Act of 2005—provided $1 million to the Institute
of Medicine. With these funds, the institute will conduct a study and provide
recommendations regarding appropriate nutritional standards for the
availability, sale, content, and consumption of all foods at school, with a
particular emphasis on competitive foods.
ALMOST ALL SCHOOLS SOLD COMPETITIVE FOODS IN

2003-2004, AND MIDDLE SCHOOL AVAILABILITY HAS
INCREASED OVER THE LAST 5 YEARS
Nearly 9 out of 10 schools sold competitive foods to students in 2003-
2004, and over the last 5 years, the availability of competitive foods has
increased both in middle schools and in a la carte lines in many schools. While
competitive foods were commonly available in all school levels, students in
high schools and middle schools had greater access to these foods than
students in elementary schools. The competitive foods available ranged from
nutritious items such as fruit and milk to less nutritious items such as soda and
candy. Between 1998-1999 and 2003-2004, the availability of competitive
foods increased in middle schools, and the volume and variety of a la carte
foods sold increased in many schools.
Competitive Foods Were Available in Almost All Schools and

Were More Common in High Schools and Middle Schools
We estimate that almost 90 percent of schools sold competitive foods to

students in 2003-2004 through one or more of the following venues: a la carte
lines, vending machines, and school stores.13 Considering each type of venue
individually, a majority of schools sold foods through a la carte lines and
vending machines, as shown in figure 3.
High schools and middle schools were more likely to sell competitive
foods than elementary schools. Table 2 shows the percentage of elementary,
middle, and high schools selling competitive foods through each type of venue
and through one or more venues.
Table 2. Estimated Percentage of Schools of Different Levels with Each

Competitive Food Venue in 2003-2004
Elementary Middle High

schools schools schools
A la carte 67 88 91
Vending machines 46 87 91
School stores 15 25 54
One or more of the above venues 83 97 99
Source: GAO.
Source: GAO.
Figure 3. Estimated Percentage of Schools Selling Competitive Foods through Each

Type of Venue in 2003-2004.
In addition to the competitive food venues regularly available in schools,

students in some schools also were able to purchase competitive foods through
on-campus fund-raisers. For example, more than 4 out of 10 schools allowed
fund-raising—such as seasonal candy sales or short-term sales of baked goods
raising revenues for school organizations—through the sale of foods to
students during the school day in 2003-2004. Such fund-raisers were permitted
in two-thirds of high schools and less than 40 percent of middle and
elementary schools.
While federal regulations restrict access to FMNV—a subset of
competitive foods—in food service areas during meal periods, many types of
competitive foods are allowed to be sold in these locations at meal times.
According to our survey, competitive foods sold in 2003-2004 through a la
carte lines, vending machines, and school stores were frequently available for
purchase in or near school cafeterias and during lunch.14
• A la carte items were available to students in the cafeterias of schools

that offered them and were available to students during lunch in 94
percent of those schools.
• One-half of schools with vending machines had machines in or near
the cafeteria, and one-third of schools with vending machines had
machines that were available to students during lunch.
• Nearly half of schools with stores had such stores in or near the
cafeteria, and about one-third of schools with stores sold competitive
foods through these stores during lunch.
Although schools that sold competitive foods through a la carte lines or

school stores often sold these foods in just one physical location, schools with
vending machines typically had multiple machines available throughout the
school, ranging from 1 to 25 machines. For example, the quarter of high
schools with the most vending machines had 10 or more machines, the top
quarter of middle schools had 7 or more machines, and the top quarter of
elementary schools had 3 or more machines.15 Schools generally had more
beverage vending machines than snack vending machines.
Further, in many schools, particularly high schools, beverages sold in
vending machines or elsewhere in the school were provided through an
exclusive beverage contract—a contract granting a company exclusive rights
to sell beverages to students in that school. In addition to covering vending
machine sales, these contracts may require schools to provide beverages
through the contracted company in other venues, such as school stores or
athletic event concessions. Nearly half of all schools in 2003-2004 had an
exclusive beverage contract. In over a third of schools with exclusive beverage
contracts, the contracts covered 5 years or more, with some covering at least
10 years.16 Nearly 75 percent of high schools, 65 percent of middle schools,
and 30 percent of elementary schools had exclusive beverage contracts.
Types of Competitive Foods Ranged from Nutritious to Less

Nutritious, with High and Middle Schools Selling a Wider
Variety of Items
Competitive foods available through a la carte lines, vending machines,

and school stores ranged from nutritious items, such as vegetables and salad,
to less nutritious items, such as soda and candy.
Table 3. Types of Competitive Foods Often or Always Available through

Each Venue in Schools, by Nutrition Category
Source: GAO.
Note: The nutrition categories, as signified by the shading, are general descriptions of the foods
in each category. GAO created these nutrition categories to generally reflect the Dietary
Guidelines for Americans, recognizing that they apply to many but not all foods of each
type—nutritional content can vary depending on the ingredients and the methods used to
prepare foods. Four of the estimates in this figure have margins of error that exceed plus or
minus 15 percent. See table 6 in appendix I for more information.
Table 4. Types of Competitive Foods Often or Always Available through

Any Venue in Schools, by School Level and Nutrition Category
Source: GAO.
Note: The nutrition categories, as signified by the shading, are general descriptions of
the foods in each category. GAO created these nutrition categories to generally
reflect the Dietary Guidelines for Americans, recognizing that they apply to many
but not all foods of each type—nutritional content can vary depending on the
ingredients and the methods used to prepare foods.
Nutritious foods were more frequently available through a la carte lines

than through vending machines and school stores. For example, as shown in
table 3, we estimate that many of the types of foods commonly available
through a la carte sales were nutritious foods and beverages, such as fruit and
milk.
However, types of less nutritious items, such as sweet baked goods and
salty snacks not low in fat, were also available through a la carte lines in at
least one-third of schools. Furthermore, many of the types of foods commonly
available through vending machines and school stores were less nutritious
ones, such as soda and salty snacks.17
In addition, our data suggest that students may have had increased access
to more types of competitive foods as they progressed from elementary school
to middle school and high school. While nutritious foods were commonly
available in schools of each level, students in high schools and middle schools
had access to a greater variety of types of less nutritious foods than students in
elementary schools. For example, salty snacks, sweet baked goods, soda, and
candy were available in at least one-third of high schools and middle schools
with competitive foods but in less than one-third of such elementary schools,
as shown in table 4.18
Over the Last 5 Years, the Availability of Competitive Foods

Sold in Middle Schools and through a la Carte Lines Increased
According to our survey, the availability of competitive food venues in

middle schools increased during the period between 1998-1999 and 2003-
2004.
• The percentage of middle schools offering competitive foods through

a la carte lines, vending machines, or school stores increased from 83
to 97 percent during this time period.19
• The percentage of middle schools with exclusive beverage contracts
increased between 1998-1999 and 2003-2004.20
• The number of vending machines per school increased between 1998-
1999 and 2003-2004 in more than one-third of middle schools that
had vending machines.21 In addition, the number of vending machines
per school increased in more than half of high schools that had
vending machines.
In addition, the availability of a la carte items, particularly the volume sold

and the variety available for purchase, increased between 1998-1999 and
2003-2004 in many schools.
• The volume of a la carte items sold—that is, the overall amount of all
a la carte items sold—increased in more than two-thirds of high
schools, more than half of middle schools, and nearly one-third of
elementary schools that had a la carte sales.22
• The variety—that is, the number of different types—of a la carte
items available to students increased in about one-half of all schools
that had a la carte sales.
According to SFA directors, reasons for the increases in a la carte volume

and variety between 1998-1999 and 2003-2004 included responding to student
demand, providing more nutritious foods, making foods more appealing to
students, and generating additional revenue for the food service.
Aside from increases in the availability of competitive foods sold in
middle school and through a la carte lines, we did not find that the availability
of competitive foods in schools changed considerably during the period
between 1998-1999 and 2003-2004. For example, according to our survey,
there have not been considerable changes in the percentage of high schools or
elementary schools offering competitive foods through a la carte lines,
vending machines, or school stores during this time period. Further, in a
majority of all schools with school stores or vending machines, the number of
different types of food offered for sale through these venues stayed the same.
MANY PEOPLE MADE DECISIONS ABOUT COMPETITIVE

FOOD SALES, BUT NO ONE PERSON COMMONLY HAD
RESPONSIBILITY OVER ALL SALES IN A SCHOOL
Many people, including district and school officials as well as members of
groups selling foods in schools, made decisions about competitive food sales,
but no one person consistently had responsibility for all competitive food sales
at the school level. The decisions ranged from broad policies about the school
nutrition environment to decisions about which foods to sell at a specific
venue or event. In 2003-2004, a majority of schools had policies in place that
restricted competitive food sales to students, and these policies were often set
at the district level by superintendents and school boards. Regarding the actual
selection and sale of competitive foods in schools, SFA directors were
commonly involved in decisions related to a la carte sales, while principals
often had final approval over other competitive food sales. In addition, many
different groups were directly involved in selling competitive foods in schools
in 2003-2004, and these groups could make decisions about which foods to
sell and when to make them available. The number and variety of groups
involved in these sales typically increased as the school level increased.
District and School Officials Made Decisions about Competitive

Food Policies
According to principals, an estimated 60 percent of schools had written

policies in place that restricted competitive foods accessible to students in
2003-2004, and most often, districts enacted those policies (see fig. 4).23 In
contrast, 40 percent of schools had no such policies.
Source: GAO.
Figure 4. Estimated Percentage of Schools with a Written Competitive Food Policy in

2003-2004 Enacted by Districts and Schools.
In addition to superintendents and school boards that were involved in

making these competitive food policy decisions for a district, both SFA
directors and school principals commonly made policy decisions about actual
food sales at the school level, resulting in no one person having responsibility
over all sales. Specifically, district SFA directors often made ongoing
decisions about policies affecting the school nutrition environment. For
example, SFA directors provided many of the foods available to students
through their administration of the federal meal programs and typically
decided which foods to serve through school a la carte sales. In addition, SFA
directors were also often concerned with other competitive food sales in the
schools, such as those through vending machines, school stores, and fund-
raising sales. According to our survey, 84 percent of SFA directors in 2003-
2004 considered addressing the competitive food environment in schools to be
part of their responsibilities. More than three-quarters of those directors
considered it a priority.
Moreover, principals also made decisions about competitive food policies
in their schools. For example, as shown in figure 4, aside from the more than
three-quarters of schools with competitive food policies developed by their
districts, school principals enacted policies in conjunction with their districts
in an additional 10 percent of schools and enacted their own policies in
another 2 percent of schools with policies. Regarding operational decisions,
principals in more than half of schools with competitive food sales reported in
our survey that they provided final approval over the foods and beverages sold
through vending machines, school stores, and fund-raisers in their schools.
Also, similar to SFA directors, principals in a majority of schools reported that
they considered addressing the competitive food environment one of their
responsibilities.
Many Different Groups Were Directly Involved in Deciding

What to Sell and Selling Competitive Foods
In addition to the district and school officials involved in decisions related

to competitive food policy, myriad individuals and groups were directly
involved in the sale of competitive foods. These groups could make decisions
about which specific foods to sell to students and when to conduct sales.
During 2003-2004, groups such as students, parent-teacher associations, and
booster groups—in addition to SFA directors and school principals—were
most commonly involved in sales, according to our survey.
The number of groups involved in sales typically increased as the school
level increased. For example, three or more different groups were much more
likely to be involved in competitive food sales in high schools than in middle
and elementary schools in 2003-2004 (see fig. 5).
Source: GAO.
Note: The estimates for elementary schools and one estimate for middle schools in this
figure have margins of error that exceed plus or minus 15 percent. See table 6 in
appendix I for more information.
Figure 5. Number of Groups Directly Involved in Competitive Food Sales in 2003-

2004, Reported as an Estimated Percentage of Schools with Sales.
The groups directly involved in sales varied by school level. In elementary

schools, the SFA/school food service and student associations/clubs were
commonly involved in sales.24 In middle schools, in addition to these groups,
school officials/administrators were most commonly involved.25 In high
schools, where the greatest number of competitive food venues was typically
available, these three groups and a variety of others were directly involved in
sales. Consequently, within a high school that has a number of competitive
food sales occurring simultaneously, a student at lunchtime could be faced
with many different food options sold by a variety of different groups through
several venues (see fig. 6).
Source: GAO analysis.

Note: The competitive food venues shown were estimated to be available in a majority
of high schools, according to our survey. The groups listed with these venues were
estimated to be directly involved in competitive food sales through the specified
venue in at least 25 percent of high schools.
Figure 6. Groups Most Frequently Involved in Various Competitive Food Venues

Commonly Available in High Schools.
MANY SCHOOLS RAISED A SUBSTANTIAL AMOUNT OF

REVENUE THROUGH COMPETITIVE FOOD SALES AND
USED IT TO SUPPORT FOOD SERVICE OPERATIONS AND
STUDENT ACTIVITIES
Many schools generated substantial revenue through competitive food
sales in 2003-2004, often using this revenue to support food service operations
and student activities. High schools and middle schools generally raised more
revenue from competitive food sales than elementary schools, reflecting the
greater availability of competitive foods in high and middle schools. Across all
competitive food sales, food services generated more revenue than other
school groups, largely through a la carte sales. Some food service directors
said they relied on this revenue to support overall food service operations,
while other school groups primarily used their competitive food revenues to
fund student activities.
Total Competitive Food Revenue Varied by School Level From

More than $125,000 in Some High Schools to More than $5,000
in Some Elementary Schools
Many schools generated a substantial amount of revenue through

competitive food sales in 2003-2004.26 Total revenue generated through
competitive food venues varied by school level, reflecting, among other
things, the greater availability of competitive foods in high schools and middle
schools than in elementary schools.27 In particular, we estimate that about 30
percent of all high schools generated more than $125,000 per school through
competitive food sales in 2003-2004, while about 30 percent of all elementary
schools generated more than $5,000 per school through these sales (see fig. 7).
These estimates of total competitive food revenue are conservative, as they are
based on the sum of the minimums of specified revenue ranges.28 Therefore,
many schools likely generated more total revenue from competitive food sales
than our analysis reflects.
Figure 7. (Continued).
Source: GAO.
Note: See appendix I for more information on this analysis, which used data obtained
from the matched responses. One of the estimates in the high school figure has a
margin of error that exceeds plus or minus 15 percent. See table 6 in appendix I
for more information.
Figure 7. Estimated Percentage of Schools Generating Different Minimum Amounts of

Total Competitive Food Revenue in 2003-2004, by School Level.
Food Services Generated More Revenue through These Sales

than Other School Groups, with Food Services Using Revenue
for Their Operations and Other School Groups Using Revenue
for Student Activities
Across all competitive food sales, food services generated more revenue
than other school groups, such as school administrators, student associations,
and booster groups.29 Specifically, food services generated a greater amount of
revenue through a la carte sales than through any other type of competitive
food sale. Other school groups raised a greater amount of revenue through
exclusive beverage contracts than through any other type of competitive food
sale.30 In addition to raising varying amounts of competitive food revenues
through different types of sales, food services and other school groups
generally used their revenues for different purposes.
Food Services
The revenue food services generated through a la carte sales was
substantial in many schools. For example, we estimate that 40 percent of high
school food services and nearly a quarter of middle school food services
selling competitive foods through a la carte lines generated more than $50,000
per school through these sales in 2003-2004. Furthermore, food services in 20
percent of high schools selling a la carte items generated more than $125,000
per school through a la carte sales, as shown in figure 8.
Source: GAO.
Note: Estimated percentages do not add to 100 because some SFA directors were
unsure how much revenue they generated through a la carte sales.
Figure 8. Estimated Percentage of High Schools in Which Food Services Generated

Different Amounts of Revenue through a la Carte Sales in 2003-2004.
Food services typically used their substantial a la carte revenue to support

overall food service operations, supplementing revenue earned through the
sale of school meals. According to our survey of SFA directors, in 2003-2004,
food services in 40 percent of schools earned less revenue than they spent,
generating a loss, and food services in an additional 20 percent of schools
broke even. Food services in the remaining 40 percent of schools generated
more revenue than they spent in 2003-2004, yielding a gain.31 From the data
we collected, it is not clear what proportion of this food service revenue came
from federal reimbursement for meals served and what proportion came from
revenue generated through competitive food sales.32 In our previous work, we
found that food services in some states had a small but increasing shortfall in
total revenue compared with expenses between school years 1996-1997 and
2000-2001 and that a la carte sales had become an increasingly important
source for augmenting total food service revenue.33 Moreover, some SFA
directors told us in survey comments for this study that they sold competitive
foods in order to maintain balanced budgets. For example, one food service
director commented that the food service would not be able to maintain a
balanced budget without the substantial revenue generated through a la carte
sales. Another commented that the district food service generated nearly half
of its revenue through competitive food sales.
Other School Groups

Other school groups raised more revenue through exclusive beverage
contracts than through any other type of competitive food sales. In particular,
we estimate that school groups in nearly one-quarter of high schools with
exclusive beverage contracts generated more than $15,000 per school through
these contracts in 2003-2004, as shown in figure 9. However, it is important to
note that 15 percent of high school principals did not know how much revenue
exclusive beverage contracts generated for their schools in 2003-2004.
Exclusive beverage contracts also provided some schools with noncash
benefits—goods and services such as athletic scoreboards and in-kind support
of school events. In particular, nearly 30 percent of schools of all levels selling
competitive foods through exclusive beverage contracts received noncash
benefits. Nearly one-third of those schools received athletic equipment,
facilities, or uniforms, and a small number of schools also received support for
assemblies and programs, scholarships, and personal items for students and
school staff, such as cups and coolers. The value of those items was sometimes
considerable: in one-quarter of those schools receiving noncash benefits
through exclusive beverage contracts in 2003-2004, the benefits were worth

more than $5,000 per school.34
Source: GAO.
Note: Estimated percentages do not add to 100 because some school principals were
unsure how much revenue other school groups generated through exclusive
beverage contracts.
Figure 9. Estimated Percentage of High Schools in Which Other School Groups

Generated Different Amounts of Revenue through Exclusive Beverage Contracts in
2003-2004.
School groups other than food services most commonly used their
competitive food revenues to support student activities such as field trips and
assemblies, as shown in figure 10. Similarly, groups in many schools spent
competitive food revenues on athletic equipment, facilities, or uniforms.
However, some used revenues to meet school needs such as expenses
associated with general school overhead or with textbooks and school
supplies.
Source: GAO.
Note: General school overhead includes facilities and grounds maintenance.
Respondents in 22 percent of schools said they spent competitive food revenues
on other uses, such as student rewards and incentives.
Figure 10. Estimated Percentage of Schools Using Competitive Food Revenue,

Excluding Food Service Revenue, for Various Purposes in 2003-2004.
SCHOOL DISTRICTS WE VISITED SUBSTITUTED HEALTHY

COMPETITIVE FOODS FOR LESS NUTRITIOUS ITEMS
WHILE OVERCOMING OBSTACLES TO CHANGE, AND THE
EFFECTS ON REVENUE WERE UNCLEAR
The six school districts we visited all recently took steps to substitute
healthy competitive foods for less nutritious items while overcoming several
obstacles to change, and in the end, the effects of these changes on revenue
were unclear. Although the districts we visited increased the availability of
healthy competitive foods and decreased less nutritious items through differing
approaches, perseverant and committed individuals took actions in each
district to initiate and lead the process of change while also taking steps to
involve and obtain support from those affected. At the same time, officials
noted that they faced several barriers to making changes, including concerns
about potential revenue losses, among others. Concerning the effects of
changes on sales revenues, none of the districts we visited had sufficient data
to examine these effects, and few had planned for these effects before
implementing changes. Regardless of the limited data on revenue, many
officials expressed strong concerns about potential revenue losses largely
because competitive food sales have provided a source of flexible funding
used for a wide variety of purposes.
School Districts We Visited Substituted Healthy Competitive

Foods for Less Nutritious Items
Though the six school districts we visited varied in terms of

socioeconomic status, student population size, and geographic location, they
were all able to take steps to restrict the availability of less nutritious
competitive foods in their schools. Further, rather than just remove less
nutritious competitive foods from their schools, these districts continued to
offer competitive foods to students by substituting healthy fare for the items
removed. In addition, these districts all took steps beyond current federal and
state competitive food regulations, and while there were differences in the
details of changes, most districts’ changes had similar characteristics.
Specifically, most, if not all, of the districts we visited
• made changes to competitive foods in all of the schools in their

districts, rather than changes only to certain schools, such as
elementary;35
• made changes to the availability of competitive foods throughout the
entire school day, rather than limiting availability only during certain
hours of the day;
• made changes to the availability of competitive foods in each of the
venues through which they were sold, including fund-raising;36and,
• made simultaneous changes to foods served through school meal

programs.
Regarding districts’ efforts to increase the availability of healthy

competitive foods, as they defined them, all of the districts we visited recently
took steps to make water and juice more available to students in their schools.
For example, districts and schools often replaced soda in their vending
machines with bottled water and juices with higher concentrations of real fruit
juice. Further, several districts also replaced fried potato chips with baked
potato chips, and packaged desserts with granola bars or similar items. Several
districts also increased the variety of flavored milk available in schools to
encourage milk consumption.
All of the districts we visited also took steps to restrict less nutritious
items. The specific types of competitive foods restricted varied by district,
with two of the districts limiting the availability of primarily soda and candy,
and four districts limiting the availability of competitive foods high in sugar
and fat.37 In these districts, different criteria were used by each district to
define foods high in sugar and fat. For example, in Fort Osage, all competitive
foods must be low-fat (no specified percentage) and cannot have sugar listed
as the first ingredient, while in Richland One, all competitive foods must
contain less than 40 percent sugar (or other sweeteners) and less than 8 grams
of fat per 1 ounce serving. In the other two districts, New Haven and
Independence, formulating specific nutrition criteria has been an ongoing
process.
In addition to making changes to the types of competitive foods sold in
schools, all of the districts we visited also made similar changes to increase
healthy foods available through school meals. For example, SFAs in both
Independence and Oakland recently removed deep fryers from school
cafeterias, and they now bake all foods. In Richland One, the SFA decided to
implement stricter standards for school meals than those required by the
federal government. Specifically, Richland One requires school meal menus to
meet the federal requirements for nutrients, fat, and sugar intake on a daily
basis, rather than averaging the nutritional value of meal components over the
course of a week. In addition, several SFA directors stated that they would like
to introduce a greater variety of fresh fruits and vegetables into school meal
menus. However, they also expressed their opinion that the federal school
meal reimbursement is insufficient to provide these items more frequently.38
Table 5. District, School, and Community Groups Involved in the Process

of Changing Competitive Foods, by District Visited
Source: GAO.
Note: In Independence, New Haven, Oakland, and McComb, some of the groups
indicated were involved in the process of changing competitive foods through
districtwide committees to address school nutrition and health issues.
Individuals Who Initiated and Led Change Also Obtained the

Support of Multiple Groups
While the characteristics of the six districts we visited differed, as well as

the process of change in each, districts typically noted several key components
to their success. These key components included an enthusiastic initiator of
change, leadership by dynamic and committed individuals, and support from
groups directly affected by changes, such as teachers, parents, and students.
Overall, those involved in the process of change agreed on the importance of
improving student nutrition and health and directing resources and energy
toward achieving this goal. As shown in table 5, the types of individuals and
groups involved in the process of change varied across the districts visited and
often included individuals from the district, school, and community.
As shown in table 5, in the districts we visited, initiators of change
sometimes came from within the ranks of district staff and sometimes from the
community, while leaders of change often were district or school staff. In
some districts, one person or group acted as both the initiator and leader of
change, while in other cases, the initiator pushed the idea of changing
competitive foods forward and then the leader took over implementation of the
changes. For example, in several districts, the superintendent or SFA director
initiated and led changes to competitive foods because of concerns about both
student nutrition and competition with the school food service. In another
district, changes were initiated and led largely by a middle school principal
and a physical education teacher. In contrast, in New Haven, a local
pediatrician who was also the district’s medical adviser initiated change to
competitive foods, and then a committee of district staff, school staff, and
community members took over leadership of changes. In all of the districts we
visited, a strong leader helped formulate new policies, reached out to parties
affected by changes, and ensured that policies were implemented.
While competitive food changes were often initiated and led by a few
individuals, all six districts realized that changes would be successful only
with the involvement of a variety of people in the process in order to ensure
their support for the changes and help sustain changes. To address this need,
some districts, such as Oakland and New Haven, convened formal committees
to provide recommendations on school nutrition and health issues. In other
districts, leaders took steps to reach out individually to those parties affected
by changes, such as school principals, teachers, and students, to obtain support
before their enactment. This support was also instrumental to sustaining
changes. For example, the McComb superintendent noted that successful
implementation of the district’s coordinated school health program required

both leadership as well as substantial community involvement, including input
from school officials and teachers, parents, and health providers in the
community. The involvement of these groups in formulating changes helped
ensure continued commitment and support of the changes.
In addition to obtaining the support of a variety of groups before
implementing changes, many districts noted that obtaining student acceptance
of the changes was particularly important to the success of change. To that
end, some districts held nutrition and health fairs to distribute related
information to students and the broader community, and others involved
students in taste testing and voting on the foods they preferred. For example,
middle school students and parents in Fort Osage taste-tested healthy
competitive foods during parents’ night and the school’s open house. In other
districts, student feedback on policy changes was sought by officials before
their implementation, sometimes by consulting the district’s student advisory
council.
Districts Faced Several Barriers to Changing Competitive

Foods, Including Schools’ Concerns about Revenue Losses
While the districts we visited all noted several key components to

successful change, they also cited several barriers to implementing changes to
competitive foods that they had commonly faced. In particular, officials in
almost all of the districts visited cited opposition because of concerns about
future revenue losses as a barrier to changing the availability of competitive
foods. In these cases, school principals most frequently expressed these
concerns because competitive food revenues often provided discretionary
money that was otherwise unavailable to fund a variety of projects and needs
at the school level.
In addition, a lack of information on other districts’ efforts to make
changes to competitive foods and a lack of nutritional guidelines for these
foods were also barriers to change in the districts we visited. While a majority
of the districts visited implemented their own changes to competitive foods
without knowledge of the steps taken by other districts to make such changes,
officials in Richland One and Oakland conducted their own research on other
state and district competitive food policies in order to learn from the
experiences of others. Related to this, officials in Independence, Fort Osage,
and New Haven noted that the lack of agreed-upon nutrition guidelines for
competitive foods was an obstacle to change because they had to

independently develop their own nutrition standards. From our observations
during these visits, the absence of a clear set of standards defining healthy and
less nutritious foods can create a problem for districts making changes to
competitive foods as continual debates and disagreements on such standards
may slow the process of policy formation, particularly when many groups are
involved in the process.
Several districts mentioned additional barriers to making changes, such as
determining the full extent of competitive food sales in schools and the groups
involved in sales. For example, the SFA director in Independence noted that
the district’s delay in developing nutrition standards for competitive foods was
largely due to the difficulty of compiling a full picture of all competitive food
sales occurring in schools. Related to this, given the number of groups that can
be involved in these sales in each school, and the lack of clear roles and
responsibilities in this environment, she noted that it has been difficult to
determine the full extent of groups involved in sales across the district. She
emphasized that it is important for the groups that have a stake in the revenues
generated by these sales to be involved in discussions concerning competitive
food policy in order to obtain support for the policy and successful
implementation of changes.
Some districts also noted that the need to continually monitor
implementation of competitive food changes at the school level can be an
obstacle to change. Officials in both Oakland and Richland One stated that
monitoring adherence to their competitive food policies at the school level has
been difficult but is necessary to effective implementation. Even when school-
level groups were involved in the process of developing changes, monitoring
policy implementation was difficult because of the involvement of many
groups in competitive food sales. In Richland One, the SFA director noted that
she often relies on observances by food service staff working in the schools to
ensure that the policy is being followed by all groups selling competitive
foods. Our own observations of the school food environment during our visits
to schools support the conclusion that districts have difficulty monitoring the
implementation of policies, as we noticed a few deviations from district
competitive food policies in some schools. Even though school officials often
seemed devoted to the goal of improving the nutritional quality of foods
available in their schools, they typically faced many competing priorities
during the school day. Further, in many schools, it was unclear who was
responsible for ensuring that policies were effectively implemented.
Food service staff in Fort Osage and New Haven stated that the difficulty
of finding healthy foods that both meet district nutrition goals and appeal to
students was also a barrier to making changes to competitive foods. They
noted that some healthy foods students found appealing were unavailable from
vendors, while in other instances, the healthy foods available were too
expensive to sell to students. This sentiment was echoed by students in several
districts, as they expressed their opinions that some of the newly introduced
healthy foods, such as bottles of flavored milk or juice, were too costly to
purchase as part of their lunch. In contrast to districts that mentioned problems
obtaining new healthy products from vendors, several districts noted that they
were able to work within their exclusive beverage contracts to obtain healthier
beverages to serve to students. However, at least one mentioned that the major
soft drink company with whom the district had a contract offered few nonsoda
options.
In addition, districts also faced the challenge of educating students about
healthy eating and encouraging students to change their behavior by choosing
healthy foods. In several of the districts, schools reported providing students
with nutrition information and education, sometimes through classroom
lessons, posters, and programs and activities to promote healthy eating. During
our visits, students we spoke with frequently demonstrated their understanding
of the importance of healthy eating, and some noted that they would like to see
the addition of certain healthy foods to school offerings, such as a greater
variety of fresh fruits and vegetables. In addition, several middle school
students in Fort Osage and New Haven explained that after changes were
made to competitive foods and they began to learn more about good nutrition
in their schools, they went home and talked to their parents about these
issues.39 However, experts agree that it is more difficult to change behavior
than to educate individuals.40 Related to this, high school students in most of
the districts we visited mentioned that some students continue to purchase less
nutritious foods before school and after school from neighborhood stores and
restaurants. In addition, during our visits to schools, we observed students
eating a wide range of both healthy and unhealthy items during lunch, with
younger students being more likely to eat healthy foods than high school
students.41
As part of their role in helping districts develop wellness policies that
address, among other things, school nutrition, USDA has recently taken
several steps that may help districts overcome some of these barriers.42 In
March 2005, USDA, in partnership with HHS/CDC and the Department of
Education, sent a letter to state superintendents, district superintendents, and
SFA directors describing the wellness policy requirements. Through this letter,
the agencies offered to provide technical assistance to districts, and they also
provided information on online resources available at the federal level to help
districts develop their policies. Specifically, these agencies, in collaboration
with several food and nutrition organizations, have begun to compile resources
that will provide districts with information on state and local efforts to make
changes to the school health and nutrition environment, including examples of
nutrition standards used by states and localities that have already developed
competitive food policies.43 In addition to online resources, these three
agencies recently released Making it Happen! School Nutrition Success
Stories, a publication that describes local efforts to address the school nutrition
environment, in order to assist districts as they move forward with their own
changes.44
The Effects of Changes to Competitive Foods on Revenues Were

Often Unclear because of Limited Data; Nonetheless, Many
Officials Expressed Concerns about Revenue Losses
In the districts we visited, reliable data on how changes to competitive

food sales affected revenues were typically unavailable. Schools and districts
often did not maintain detailed revenue records to enable the type of analyses
needed to parcel out the direct effects of competitive food changes on
revenues. Nonetheless, most schools and districts were able to provide partial
data on revenue changes for specific venues, and these limited data suggest
that districts experienced mixed revenue effects. Several schools we visited
appear to have lost revenue from competitive food sales after they made
changes, while at least one may have increased revenue. For example, after
increasing the availability of healthy a la carte foods and restricting less
nutritious items, SFA directors in both Independence and Richland One
recorded decreases in a la carte sales. In contrast, a middle school in McComb
reported that after removing soda from beverage vending machines and
changing the policy regarding the times sales were allowed, vending revenues
increased. However, these data did not account for other factors that may also
have affected revenues.
While the limited data available suggest that school districts experienced
mixed revenue effects after implementing competitive food changes, they also
illustrate the difficulty of tracking these effects. Because the competitive food
environment is complex, sometimes involving many sales and many groups,
the effects of changes on revenues are often complicated and may differ for
each group involved in sales. Some groups may benefit from changes, others
may lose. For example, in Fort Osage, when the middle school decided to
remove all less nutritious competitive foods available in the school and replace
them with healthy items, it also simultaneously decided to stop using outside
vendors to supply its vending machines. Subsequently, the district SFA took
over operation of the middle school’s vending machines, and as a result,
vending revenue began to accrue to the SFA instead of school administrators.
While the SFA director was unable to compare the revenue before changes
with that generated after changes, she reported that the machines were self-
supporting. In this instance, because of the changes made to competitive foods
and their sale, school administrators lost a source of revenue while the SFA
gained one.
In addition to the challenge of understanding the revenue effects of
competitive food changes on different groups in schools, the relationship
between changes in a la carte sales and school meal participation adds
complexity. Although food service programs rely on reimbursement for school
meal participation as a primary source of funding, officials often cite the
importance of using additional revenue from a la carte sales to balance their
budgets. Therefore, officials take risks when they make changes to the
competitive foods available in schools, because changes may affect revenues
from these sales and they may also affect school meals participation. In the
districts we visited, competitive food changes were often accompanied by
increased school meals participation. In four districts, federal reimbursements
for meals subsequently increased, benefiting the SFA, and in at least one
instance, this increase more than made up for food service losses in
competitive food sales. While Richland One reported losing approximately
$300,000 in annual a la carte revenue after implementing changes, school
lunch participation and subsequent federal reimbursements increased by
approximately $400,000 in the same year.
Despite the lack of conclusive data on revenue effects, district and school
officials often expressed strong concerns about potential revenue losses.
Because food services often operate on tight budgets and use competitive food
revenues to support their operations, they take the risk of losing important
revenues when they make changes to these foods.45 In addition, principals
frequently stated that competitive food revenues are used at the school level as
discretionary funding, and they do not typically have other sources of flexible
funding available to use for the wide variety of purposes toward which
competitive food revenues are directed. Therefore, when making changes to
competitive foods, principals also risk losing what is an oftentimes important

source of funding. For example, in the schools we visited, many principals
reported using competitive food revenues for student activities and classroom
supplies, and some reported using these revenues to support school dances and
assist needy students.
Although data on revenue effects were limited and complicated by the
complex competitive food environment in the districts we visited, some
districts tried to lessen adverse revenue effects by the process through which
changes to competitive foods were implemented. Specifically, a few districts
and schools reported taking incremental steps to change competitive foods in
order to mitigate the severity of the effects on revenue. For example, in one
Independence high school, incremental changes were being made to beverage
vending machines to phase in juice and water and phase out soda over a span
of several years. The high school principal reported that the school was
conducting this change slowly in order to avoid surprising students with
sudden changes and to maintain revenue. In addition, a few schools noted that
their efforts to include students in decisions about changing food offerings
may have helped ensure that the new foods would be accepted by students and
mitigate the effects on revenues. However, many of the districts we visited did
not fully plan for the effects on sales revenues when they were considering
changes to competitive food policy, and several recognized that efforts to do
so would have likely eased the implementation of policies. Moreover, some
principals reported that their schools were able to find ways to support projects
previously funded with competitive food sales after changes were
implemented. For example, in several districts, principals reported that after
restrictions on fund-raiser food sales were implemented, groups sold nonfood
items like wrapping paper and candles, and also raised funds by providing
services, such as car washes.
In the publication Making it Happen! School Nutrition Success Stories,
key contacts in selected schools reported similar mixed revenue results from
their efforts to improve the school nutrition environment.46 Of the group of
schools that reported on revenue changes, some experienced increases in
revenue while others reported decreases or no change. These schools used
approaches similar to those in the schools we visited, such as replacing less
nutritious food with more nutritious choices, obtaining input from the students,
and using marketing to encourage students to make healthy choices. In
addition, several of the schools reported increases in school meal participation.
CONCLUSION
Our nation’s schools are uniquely positioned to positively influence the
eating habits of children, yet almost all schools sell readily available foods that
are largely unregulated by the federal government in terms of nutritional
content. While not all of these competitive foods are unhealthy, many are.
Although schools cannot be expected to solve the current problems with child
nutrition and growing obesity alone, many states and districts have begun
efforts to improve the nutritional environments in their schools.
As districts across the country develop their required wellness policies by
school year 2006-2007, they will likely face decisions and challenges similar
to those of the districts we studied and may benefit from their lessons learned.
Although each district took a different approach, all of them recognized the
value of including those parties affected by the changes, such as parents,
teachers, and other community members, when developing new policies. In
addition, they recognized that students are the ultimate consumers of
competitive foods and took steps to consider their opinions.
Because districts reported they typically lacked a source of recommended
nutrition standards for competitive foods in schools, officials were faced with
difficult decisions about the criteria they would use to determine which foods
were considered adequately nutritious to offer. The technical assistance
available from FNS, including multiple examples of nutrition standards
developed by other districts, as well as the Institute of Medicine’s forthcoming
recommendations on nutritional standards for foods in schools, should help
district efforts to address this issue.
In addition, given the multiple groups that rely on sales of competitive
foods for revenue, districts may choose to consider the possible revenue
effects of changes in food offerings as they develop and implement new
policies. Since competitive food revenues are often critical to food service
operations and provide principals with flexible funds relied on for a multitude
of discretionary purposes, making changes to competitive foods entails risks
for both groups. Districts we visited took varied steps that may mitigate
potential revenue changes, such as substituting healthy foods for less healthy
ones instead of removing all competitive foods, asking students to taste and
approve the more nutritious foods, offering alternate means for fund-raising, or
implementing change gradually. Lack of support from the groups that use
revenue from competitive food sales can scuttle policy changes. Furthermore,
the lack of a single person responsible for the presence and sale of competitive
foods in schools complicates efforts to ensure that new policies will be
implemented as intended and maintained over time. Despite the complex food
environment in schools, new wellness policy requirements and USDA’s efforts
to provide technical assistance to districts will provide an opportunity for
districts to plan and implement changes that recognize the needs of the various
groups and assign individuals with responsibility for consistent and sustained
implementation.
AGENCY COMMENTS
We provided a draft of this report to the U.S. Department of Agriculture
for review and comment. On June 17, 2005, FNS officials provided us with
their oral comments. The officials stated that they were in general agreement
with the findings as presented in the report and offered technical comments
that we have incorporated as appropriate. In addition, the officials reiterated
that the 1983 court decision in National Soft Drink Ass’n v. Block is significant
because they believe it severely limits USDA’s ability to restrict the sale of
competitive foods. FNS officials pointed out that prior to this ruling, USDA
regulations prohibited the sale of FMNV anywhere in the school from the
beginning of the school day until the last meal period. Following the decision,
USDA restricted the sale of FMNV only in food service areas during meal
periods. We agree that this ruling limited USDA’s ability to regulate
competitive food sales as to time and place. However, we believe the
department has the authority to expand the definition of FMNV to include
additional foods with limited nutritional value. Doing so could further limit the
types of these foods available in the cafeteria during meal times.
Second, officials discussed what is known about the use of revenue from
competitive food sales and reimbursable meals compared to their costs. We
did not determine if revenues generated by competitive food sales were
sufficient to cover the actual cost of the competitive foods sold. The officials
stressed that the 1994 School Lunch and Breakfast Cost Study, the last
definitive study of cost and revenue in the NSLP and the School Breakfast
Program, found that regardless of size, most school food authorities failed to
generate enough revenue to cover the reported costs of nonreimbursable food
sales.47 The mean reported revenue-to-cost ratio was 71 percent for the study
period. The officials noted that this would equate to a loss of 41 cents for
every dollar received from the sale of nonreimbursable foods. Further, this
revenue-to-cost ratio did not include all costs for school food service
operations, such as uncharged labor costs, indirect costs, and utilities. If these
were included, the revenue to cost ratio would generate even higher losses.
FNS informed us that they are in the process of contracting for a new school
meal cost study.
We agree with FNS that our report focused on revenues generated by
competitive food sales and that we did not determine if revenues generated by
competitive food sales were sufficient to cover the actual cost of the foods
sold. However, our report and others have shown that the availability of
competitive foods, and particularly a la carte items, has increased over time. In
addition, the Cost Study’s definition of nonreimbursable meals included food
sales such as adult meals and special functions, as well as competitive foods,
and therefore, it is unclear how each of these types of sales contributed to the
mean reported revenue-to-cost ratio. Absent more current information on the
actual costs and revenues of providing competitive foods and reimbursable
school meals, we believe it is difficult to know whether the results of the 1994
study are applicable today.
David D. Bellis
Director, Education, Workforce,
and Income Security Issues
APPENDIX I: SCOPE AND METHODOLOGY

To obtain nationally representative information on competitive food
availability, policies, decision makers, groups involved in their sale, and
revenues generated by their sale, we conducted two Web-based surveys. In
addition, to gather information on strategies used by school districts to restrict
less nutritious competitive foods in their schools, we visited six school
districts. Further, to inform the design of our study, we spoke with staff at the
U.S. Department of Agriculture (USDA) as well as the Centers for Disease
Control and Prevention (CDC). We also interviewed numerous researchers and
organizations that have been involved with child nutrition and school health
environment issues in recent years.1
Surveys
To better understand competitive foods in the school environment, we

designed and administered two Web-based surveys. For a random sample of
schools, we administered one survey to each school’s school food authority

(SFA) director and a second survey to each school’s principal. We chose to
survey these officials because we believed they would be the most
knowledgeable sources on competitive food issues in schools. The surveys
were conducted between October 19, 2004, and February 11, 2005. We
defined competitive foods as all foods or beverages sold to students on school
grounds during the school day that are not part of federally reimbursable
school meals.
While neither survey asked questions about the full range of competitive
food issues, together the two surveys were designed to provide a broad picture
of the competitive food environment. Both Web surveys contained school
background, a la carte, (beverage and snack) vending machine, and school
store and snack bar sections. However, each survey had unique sections as
well. The SFA directors’ survey included sections that asked questions about
the SFA, the school food service, and school meals participation. The
principals’ survey included unique sections on school and district policies for
competitive foods, including fund-raising and exclusive beverage contracts.
A majority of the survey questions asked both SFA directors and
principals to consider school year 2003-2004. To gain a sense of change for
certain competitive food issues, a few questions asked SFA directors and
principals to consider school year 1998-1999 alone, make comparisons
between these reporting periods (1998-1999 versus 2003-2004), or consider
change in specific competitive food issues over the entire time of these
reporting periods (from 1998-1999 to 2003-2004).
Population
The target population consisted of all public schools in the 50 states and
the District of Columbia that participated in the National School Lunch
Program (NSLP) for the 2003-2004 school year. We used the Department of
Education’s Common Core of Data (CCD) Public Elementary/Secondary
School preliminary file for the 2002-2003 school year as a basis for defining
our population. On the basis of our review of these data, we determined this
source to be adequate for the purposes of our work.
To define our sampling frame, we removed schools from the CCD that
were permanently or temporarily closed; not yet operational; special
education, vocational education, or alternative/other; run by the Department of
Defense or Bureau of Indian Affairs; or located in American Samoa, Guam,
Northern Marianas, Puerto Rico, or the Virgin Islands. From this analysis, we
obtained a sampling frame consisting of 85,569 regular public schools in the
50 states and the District of Columbia. However, consistent information
specifically identifying a school’s participation in the NSLP was not available
in the CCD.
Sample Design and Errors
The sample design for the Web surveys was a stratified random
probability sample of 656 schools that allows for estimates to be calculated for
each school level (elementary, middle, and high). We stratified by school
level, census region, and rural status, and we produced estimates by school
level. With this probability sample, each school in the population had a
known, nonzero probability of being selected. Each selected school was
subsequently weighted in the analysis to account statistically for all the
schools in the population, including those that were not selected. Because each
school was randomly chosen, some SFA directors had more than one school
under their responsibility selected for our study, and they were therefore asked
to complete a separate survey for each school.
Because we surveyed a sample of schools, our results are estimates of a
population of schools and thus are subject to sample errors that are associated
with samples of this size and type. Our confidence in the precision of the
results from this sample is expressed in 95 percent confidence intervals, which
are expected to include the actual results in 95 percent of the samples of this
type. We calculated confidence intervals for this sample based on methods that
are appropriate for a stratified probability sample.
Through a telephone survey of the schools selected in our sample, we
determined the number of schools selected in our sample that participated in
the NSLP. We estimate that 80,245 (94 percent) schools in our population
participated in the NSLP. All estimates produced from the sample and
presented in this report are for the estimated target population of 80,245
schools that participated in the NSLP. All percentage and numerical estimates
included in this report have margins of error of plus or minus 15 percentage
points or less, except for those shown in table 6.
Table 6. Sampling Error Calculations for Questions in Which the Error

Exceeded 15 Percent
Page Question Estimate Lower Upper

bound bound
15 Percentage of elementary schools with
vending machines that had three or more
vending machines in school year 2003-
2004 29 15 47
17 Percentage of schools with school stores
in which salty snacks (not low-fat) were
often or always available for students to
purchase from these stores in school year
2003-2004 45 29 61
in which sports drinks were often or
always available for students to purchase
from these stores in school year 2003-
2004 44 28 60
in which sweet baked goods (not low-fat)
were often or always available for
students to purchase from these stores in
school year 2003-2004 40 25 56
in which water was often or always
available for students to purchase from
these stores in school year 2003-2004 47 32 62
20 Percentage of middle schools with
vending machines in which the total
number of vending machines on school
grounds increased between school years
1998-1999 and 2003-2004 39 25 54
20 Percentage of elementary schools with a
la carte sales in which the total volume of
a la carte items sold to students increased
between school years 1998-1999 and
2003-2004 31 19 47
one group directly involved in
competitive food sales in school year
2003-2004 36 19 56
Table 6. (Continued)
Page Question Estimate Lower Upper

bound bound
two groups directly involved in
2003-2004 35 20 53
three or more groups directly involved in
2003-2004 29 14 48
24 Percentage of middle schools with two
groups directly involved in competitive
food sales in school year 2003-2004 29 17 44
SFA/school food service directly
involved in competitive food sales in
school year 2003-2004 62 45 77
student associations/clubs directly
involved in competitive food sales in
school year 2003-2004 35 19 52
24 Percentage of middle schools with school
officials or administrators directly
involved in competitive food sales 35 21 51
28 Percentage of high schools that generated
total minimum combined revenue of
$25,001 to $50,000 through competitive
food sales in school year 2003-2004 21 9 37
32 Percentage of schools with exclusive
beverage contracts that received noncash
benefits through these contracts that were
valued at over $5,000 in school year
2003-2004 25 13 41
Source: GAO.
Nonsampling Errors
We took steps to minimize nonsampling errors that are not accounted for
through statistical tests, like sampling errors. Nonsampling errors could figure
into any data collection effort and involve a range of issues that could affect
data quality, including variations in how respondents interpret questions and
their willingness to offer accurate responses.
In developing the Web surveys, we conducted several pretests of draft

instruments. We held pretest discussions of the principals’ survey with staff
and members of the National Association of Elementary School Principals and
the National Association of Secondary School Principals. We pretested the
SFA survey with members of the American School Food Service Association
(now known as the School Nutrition Association). In addition, both surveys
were also pretested during a preliminary visit to the SFA and an elementary
school in Fairfax County, Virginia. All pretests were conducted between July
and September 2004.
For the survey pretests, we were generally interested in the clarity of the
questions and the flow and layout of the surveys. For example, we wanted to
ensure definitions used in the surveys were clear and known to the
respondents, categories provided in closed-ended questions were complete and
exclusive, and the ordering of the survey sections and the questions within
each section was appropriate. On the basis of our pretests, the Web
instruments underwent some slight revisions.
After the survey was closed, we also made comparisons between select
items from our competitive food Web-based survey data and other national-
level data sets.2 Our comparisons found our survey data were reasonably
consistent with the external sources. Of the basis of our comparisons, we
believe our survey data are sufficient for the purposes of our work.
Using Web-based surveys also helped remove error in our data collection
effort. By allowing respondents to enter their responses directly into an
electronic instrument, this method automatically created a record for each
respondent in a data file and eliminated the need for and the errors (and costs)
associated with a manual data entry process. To further minimize errors,
programs used to analyze the survey data and make estimations were
independently verified to ensure the accuracy of this work.
Response Rates
For each school in our sample, we attempted to obtain valid e-mail
addresses for the principal and the SFA director. For the 656 schools in our
sample, we obtained valid e-mail addresses for 489 principals and 455 SFA
directors. We administered the surveys to those groups, and we received
completed surveys from 70 percent of the SFA directors and 65 percent of the
principals who received the surveys. The response rates for our sample of 656
schools, including those officials we were unable to contact, were 51 percent
for both principals and SFA directors, excluding the 26 non-NSLP schools.
We received responses from both the SFA director and the principal for the
same school (matched responses) for 192 schools (30 percent of schools that
participated in the NSLP in our sample). Tables 7 and 8 summarize the
population and sample by school level for the SFA director and principal
surveys respectively.
Table 7. SFA Director Survey: Population and Sample by School Level
Schools in Schools in Non-NSLP No valid NSLP schools NSLP

population sample schools e-mail surveyed schools
School level responding
Elementary 51,997 188 6 55 127 85
Middle 15,737 188 3 45 140 96
High 14,979 188 6 48 134 103
Other 2,856 92 11 27 54 35
Total 85,569 656 26 175 455 319
Source: GAO.
Table 8. Principal Survey: Population and Sample by School Level
Schools in Schools in Non- No NSLP NSLP

School
population sample NSLP valid schools schools
level
schools e-mail surveyed responding
Elementary 51,997 188 6 39 143 88
Middle 15,737 188 3 39 146 91
High 14,979 188 6 41 141 96
Other 2,856 92 11 22 59 42
Total 85,569 656 26 143 489 317
Source: GAO.
While the majority of our estimates are calculated based on survey

responses from either the SFA directors’ survey or the principals’ survey, we
used the matched responses (192 schools) to calculate the total combined
minimum revenue estimates. Specifically, the amount of revenue earned from
each competitive food venue within a school was reported by SFA directors
and principals in multiple ranges. For example, SFA directors reported
revenue generated by food services through competitive food sales, such as a
la carte sales, and principals reported revenue generated by all other
competitive food sales in the school. To estimate the combined competitive
food revenue for a school, we defined the minimum for each of the school’s
venues as the lower bound of the revenue range reported by SFA directors and
principals. We then summed the minimum revenue across all venues for each
school.
Survey Nonresponse Issues

Another type of nonsampling error is nonresponse or, in the case of our
work, those SFA directors and principals from schools in our sample who did
not provide a complete survey. To increase survey responses, after the Web
surveys were initially deployed, we made several follow-ups with
nonrespondent SFA directors and principals via e-mail and phone to remind
them of their respective surveys.
After the surveys were closed, we analyzed each set of survey respondents
(SFA directors, principals, and the matched responses) to determine if there
were any differences between the responding schools, the nonresponding
schools, and the population.3 We performed this analysis for four
characteristics—total number of students enrolled, total number eligible for
free lunch, total number eligible for reduced price lunch, and total number
eligible for either free or reduced price lunch. We determined whether sample-
based estimates of these characteristics compared favorably with the known
population values, and we also tested the differences of the estimates for
survey respondents and nonrespondents. We performed this analysis for all
schools and separately for each school level (high, middle, and elementary).
For each set of survey respondents, the population value for all of the
characteristics we examined fell within the 95 percent confidence intervals for
the estimates. We also determined that there were no significant differences
between estimates from the respondents and nonrespondents.
Additionally, we compared the distribution of several demographic
variables, including region, school level, and rural status, for survey
respondents and nonrespondents. On the basis of this analysis, we found no
significant distributional differences between respondents and nonrespondents.
Although the characteristics were selected because they may be related to
other school characteristics asked for on our surveys, we do not know the
extent to which the respondents reflect the population characteristics for our
specific survey questions. On the basis of both sets of analyses, we chose to
include the survey results in our report and produce sample-based estimates to
the population of schools that participated in the NSLP.
Site Visits
To gather information on local efforts to restrict the availability of less
nutritious competitive foods, we conducted site visits to six districts between
September 21 and December 9, 2004. The districts visited included
Independence School District (Independence, Missouri), Fort Osage R-1
School District (Independence, Missouri), New Haven Public Schools (New
Haven, Connecticut), Richland County School District One (Columbia, South

Carolina), Oakland Unified School District (Oakland, California), and
McComb School District (McComb, Mississippi). We selected these districts
from a list of approximately 100 districts and schools recognized as making
efforts to restrict access to less nutritious competitive foods. This list was
compiled by reviewing recently released reports, studies, and articles that
described local efforts to make changes to competitive foods. The six districts
visited were selected because they used different strategies to restrict
competitive foods, and when viewed as a group, they provided variation across
characteristics such as geographic location, district size, and socioeconomic
status.
During the site visits, we interviewed district officials, including the
superintendent and SFA director, as well as visited one or two schools within
each district. At the schools, we interviewed principals, food service staff, and
health and physical education teachers, as well as others involved with the
school food environment. From these interviews, we gathered information on
the district and school food environment, strategies used to restrict competitive
foods, individuals and groups involved in implementing changes, facilitators
and barriers to change, revenues generated by competitive foods, ongoing
efforts, students’ reactions to changes, and opinions on the school wellness
policies mandated in the 2004 Child Nutrition and WIC Reauthorization Act.
In addition to our interviews with district and school officials, we also met
with students to collect their opinions regarding nutrition and healthy eating,
competitive foods in schools, and school meals. Further, we observed at least
one lunch period in each school visited, in order to better understand the
school nutrition environment and the choices students make at lunch.
End Notes
1
See GAO, School Meal Programs: Competitive Foods Are Available in Many Schools; Actions
Taken to Restrict Them Differ by State and Locality, GAO-04-673 (Washington, D.C.:
April 23, 2004).
2
These percentages reflect those principals and SFA directors who actually received the Web
surveys. We were unable to contact a subset of principals and SFA directors selected in our
sample of 656 schools. See appendix I for detailed information on response rates for each
survey.
3
These data are based on the fiscal year 2004 average daily participation in the NSLP and the
School Breakfast Program, according to the FNS Program Information Report for
December 2004 from USDA.
4
These requirements for the federal meal programs were established by Congress in 1994
through the passage of the Healthy Meals for Healthy Americans Act, Pub. L. No. 103-448,
§ 106 (1994).
5
FMNV are defined in regulations for the NSLP (7 C.F.R. § 210.11) and listed in appendix B of
those regulations. USDA has the authority to change the definition of FMNV and also has
established procedures to amend the list of these foods.
6
According to regulations, all income from the sale of competitive foods in the food service area
must accrue to the nonprofit food service provider, the school, or an organization approved
by the school.
7
See GAO-04-673 for more information on the type and extent of restrictions implemented by
state competitive food policies in place as of March 2004.
8
For example, some states restrict competitive foods for one half hour before and after each
school meal period, while others restrict competitive foods from the start of the school day
until the end of the last lunch period.
9
For more information on federally funded nutrition education programs, including Team
Nutrition, see GAO, Nutrition Education: USDA Provides Services through Multiple
Programs, but Stronger Linkages among Efforts Are Needed, GAO-04-528 (Washington,
D.C.: April 27, 2004).
10
In addition, USDA published its School Nutrition Dietary Assessment Study II in 2001,
providing information on the nutritional quality of meals served in public schools that
participate in the NSLP and the School Breakfast Program. This study found that students in
school year 1998-1999 had access to a variety of breakfast and lunch options other than the
federal meal programs.
11
CDC also reported in its 2000 School Health Policies and Programs Study that competitive
foods were widely available in schools.
12
WIC is the acronym commonly used to refer to the Special Supplemental Nutrition Program
for Women, Infants, and Children.
13
We asked survey respondents questions about “school stores and/or snack bars.” Throughout
this report, we will use the term “school stores” to refer to both school stores and snack
bars.
14
A la carte foods, vending machines, and school stores were also available in some schools
during other periods of the school day. In addition, vending machines and school stores
were available in other locations in some schools, such as outside school buildings.
15
The elementary school estimate has a margin of error that exceeds plus or minus 15 percent.
See table 6 in appendix I for more information.
16
While contracts could be negotiated by the school district, the school, the school food service,
or a combination of those groups, over half of schools with exclusive beverage contracts
had a contract that was negotiated with the school district.
17
While the federal government prohibits the sale of soda and certain candy in cafeterias and
food service areas during mealtimes, these foods can be sold in other locations and during
other periods of the school day. Other less nutritious items, such as sweet baked goods and
salty snacks, can be sold in any school location during any period of the day.
18
However, less nutritious foods were available in some elementary schools. For example, frozen
desserts not low in fat were available in nearly a quarter of elementary schools with
competitive foods.
19
For this analysis, we compared the percentage of middle schools that had any competitive food
venues between school years 1998-1999 and 2003-2004 with the percentage that had any
venues in 2003-2004.
20
According to our survey, the percentage of middle schools with exclusive beverage contracts
increased to 65 percent in 2003-2004 from 26 percent in 1998-1999. An additional 31
percent of middle school principals were unsure if their school had an exclusive beverage
contract in 1998-1999.
21
This estimate has a margin of error that exceeds plus or minus 15 percent. See table 6 in
22
The elementary school estimate has a margin of error that exceeds plus or minus 15 percent.
See table 6 in appendix I for more information.
23
We did not collect information on the type and extent of restrictions placed on competitive
foods by these policies or on the enforcement of these policies.
24
The estimates for SFA/school food service and student associations/clubs have margins of
error that exceed plus or minus 15 percent. See table 6 in appendix I for more information.
25
The estimate for school officials/administrators has a margin of error that exceeds plus or
minus 15 percent. See table 6 in appendix I for more information.
26
Throughout this report, revenue for each type of competitive food venue includes all revenue
generated through competitive food sales. We did not ask survey respondents for
information on profits retained after covering expenses.
27
While the number of students in each school likely affects the amount of revenue generated
through competitive foods, our data do not allow us to determine the effect of school size on
revenue.
28
Total revenue reflects the combined minimums of revenue ranges reported by schools for a la
carte lines, vending machines, school stores, and exclusive beverage contracts. To conduct
this analysis, we used matched survey responses, which combined the principal and SFA
director’s responses for each specific school. We defined the minimum for each venue as
the lower bound of the revenue range selected by the respondent, and we then summed the
minimum revenues across all venues for each school. See appendix I for a description of
this analysis.
29
For the purposes of this discussion, revenue generated by food services refers to revenue that
was raised by both the school and district food services.
30
Many schools also held fund-raisers to generate revenue for activities and programs, but this
revenue is difficult to measure because of the involvement of numerous groups, and it is not
included in our analysis.
31
In addition, food services in 20 percent of schools received supplemental funds from the
district or school in 2003-2004, while food services in 21 percent of schools transferred
funds to the district or school in that year.
32
Further, because we did not collect information on total school food service revenue, we were
not able to compare food services’ competitive food revenue with their total revenue in
2003-2004 in order to determine the effect of competitive food revenue on food service
budgets.
33
GAO, School Meal Programs: Revenue and Expense Information from Selected States, GAO-
03-569 (Washington, D.C.: May 9, 2003). This report analyzed revenue and expense data
from six selected states.
34
This estimate has a margin of error that exceeds plus or minus 15 percent. See table 6 in
35
We selected Fort Osage School District as one of our site visits because of the changes made to
competitive foods at Fire Prairie Middle School, and all references to Fort Osage in this
report reflect only the changes made at Fire Prairie.
36
The only exception to this was Independence, where districtwide changes had been made to
only those competitive foods sold by the SFA through a la carte lines and vending machines
at the time of our visit.
37
Independence, one of the four districts restricting competitive foods high in sugar and fat,
restricted many, but not all, of these foods. Further, as noted earlier, Independence made
changes to only those competitive foods sold by the SFA.
38
In recognition of the importance of fruits and vegetables in children’s diets, Congress included
the Fruit and Vegetable Pilot Program in the 2002 Farm Bill and expanded and made the
program permanent in the 2004 Child Nutrition and WIC Reauthorization Act. This
program provides federal grants to schools in eight states and on three Indian reservations to
provide free fruits and vegetables to students in order to improve student nutrition and
introduce healthy snack options.
39
Related to this, students we met with made comments reflecting their awareness that, in
addition to schools, families and the broader community play a key role in teaching children
about good nutrition.
40
For more information on federally funded nutrition education programs and efforts to increase
healthy eating in schools, see GAO-04-528 and GAO, School Lunch Program: Efforts
Needed to Improve Nutrition and Encourage Healthy Eating, GAO-03-506 (Washington,
D.C.: May 9, 2003).
41
Specifically, we noticed that pizza appeared to be the most popular item purchased for lunch
by students in almost all of the schools we visited. Burgers and fresh fruits and vegetables
appeared to be the next most popular items, as they were purchased and eaten by students
during lunch in almost half of the schools we visited. In the lunch periods we observed,
these foods were sometimes sold as competitive foods and were sometimes served as
components of the school lunch.
42
McComb used federal resources to assist its own process of changing competitive foods.
Changes in McComb were modeled on the CDC-developed coordinated school health
model.
43
USDA stated that Action for Healthy Kids, the School Nutrition Association, and the Food
Research and Action Center are among the organizations that have assisted with these
efforts.
44
Food and Nutrition Service, USDA; CDC, HHS; and the U.S. Department of Education.
Making it Happen! School Nutrition Success Stories. Alexandria, Va., January 2005.
45
In the districts we visited, most SFA directors did not express concerns about potential revenue
losses resulting from changes to competitive foods, possibly because they were often
significantly involved and invested in the process of making these changes.
46
This publication contains self-reported information by key contacts from 32 schools and
districts nationwide.
47
Abt Associates, Inc. School Lunch and Breakfast Cost Study–Final Report, a special report
prepared at the request of USDA (Cambridge, Mass.: October 1994).
End Notes for Appendix I

1
We spoke with staff of Mathematica Policy Research Inc., Abt Associates Inc., Nutrition for the
Future Inc., University of Minnesota—School of Public Health, School Nutrition
Association, the National Association of Secondary School Principals, the National
Association of Elementary School Principals, Samuels & Associates, the Association of

School Business Officials International, the Council of Chief State School Officers, the
National Association of State Boards of Education, and the National School Boards
Association.
2
We compared our Web-based survey data to data on competitive foods reported by USDA in
the School Nutrition and Dietary Assessment Study II (1998-1999) and the School Meals
Implementation Initiative— Third Year Report (2002), and by CDC in the School Health
Policies and Programs Study (2000).
3
Nonresponding schools include both schools for which we were unable to obtain valid email
addresses and schools that received the survey but did not respond.
Chapter 3
COMPETITIVE FOODS AND BEVERAGES

IN U.S. SCHOOLS: A STATE
POLICY ANALYSIS ∗
Centers for Disease Control and Prevention
INTRODUCTION
Since 1980, the prevalence of obesity among U.S. children and
adolescents has tripled, and today 19.6% of children aged 6–11 years and
18.1% of adolescents aged 12–19 years are categorized as obese.[1] Because
youth spend a significant amount of their day in school, it is an ideal venue to
promote obesity prevention efforts. A growing body of research has found that
the school food environment is associated with youth dietary behaviors and
obesity.[2–6]
Schools can play a critical role by establishing a safe and supportive
environment with policies and practices that sustain healthy behaviors. In
addition, schools provide opportunities for youth to learn about and practice
healthy eating and physical activity.
U.S. students are exposed to a broad range of foods and beverages through
reimbursable school meals, à la carte lines, vending machines, school stores,
classroom parties, fundraisers, and other school events. Nutrition standards for
∗
This is an edited, reformatted and augmented version of Centers for Disease Control and
Prevention publication, dated 2012.
116 Centers for Disease Control and Prevention
federally reimbursable school meals are regulated by the U.S. Department of

Agriculture’s National School Lunch Program and School Breakfast
Program.[7,8]
Current federal regulations for competitive foods, which are those foods
sold or available in schools outside of federally reimbursable school meals
programs, prohibit the sale of foods of minimal nutritional value (FMNV)
(e.g., chewing gum, carbonated soft drinks, certain candies) during meal
periods in the food service area, where reimbursable school meals are sold or
eaten.[7,8]
However, no federal regulations exist for other competitive foods that are
also high in calories, fat, sodium, and sugar, but which are not specifically
identified as FMNV.
In December 2010, Congress enacted the Healthy, Hunger-Free Kids Act
of 2010, which requires the development of federal nutrition standards for all
competitive foods sold in schools. (For more information, see www.gpo.gov/
fdsys/pkg/BILLS-111s3307enr/pdf/BILLS-111s3307enr.pdf.)
Competitive foods and beverages are widely available in schools.[4,9]
State and local education agencies have the ability to set rules for competitive
foods (including FMNV) that are more stringent than federal regulations. For
example, states can prohibit the sale of FMNV on the entire school campus for
the entire school day, or they can set policies regulating the nutritional content
of all competitive foods and beverages in schools.
The Healthy, Hunger-Free Kids Act of 2010 also requires local
educational agencies to include nutrition guidelines for competitive foods in
schools as part of their local wellness policies. However, because federal
officials have not had the authority to create required standards for the content
of these guidelines, local policies for competitive foods vary widely in strength
and comprehensiveness.[10]
PURPOSE
CDC analyzed requirements included in state laws, regulations, and
policies related to the availability and nutritional content of competitive foods
in schools on the basis of how closely they align with the recommendations in
the Institute of Medicine’s (IOM’s) Nutrition Standards for Foods in Schools:
Leading the Way Toward Healthier Youth (IOM Standards).[11] The IOM
Standards for competitive foods and beverages in schools are not required by
Competitive Foods and Beverages in U.S. Schools 117
any federal mandate, but they serve as the gold standard recommendations for
the availability, sale, and content of competitive foods in schools.
The IOM Standards report concluded that
• Federally reimbursable school meals programs should be the main

source of nutrition in schools.
• Opportunities for competitive foods should be limited.
• If competitive foods are available, they should consist primarily of
fruits, vegetables, whole grains, and nonfat or low-fat milk and milk
products.
INSTITUTE OF MEDICINE NUTRITION

STANDARDS FOR FOODS IN SCHOOLS
Standards for Nutritive Food Components
1. Snacks, foods, and beverages meet dietary fat criteria per portion as
packaged: no more than 35% of total calories from fat, less than 10%
of total calories from saturated fat, and zero trans fat.
2. Snacks, foods, and beverages provide no more than 35% of calories
from total sugars per portion as packaged. Exceptions to the standard
are
a) 100% fruits and fruit juices in all forms without added sugars.
b) 100% vegetables and vegetable juices without added sugars.
c) Unflavored nonfat and low-fat milk and yogurt. Flavored nonfat
and low-fat milk can contain no more than 22 grams of total
sugars per 8-ounce portion, and flavored nonfat and low-fat yogurt
can contain no more than 30 grams of total sugars per 8-ounce
serving.
3. Snack items are 200 calories or less per portion as packaged, and à la
carte entrée items do not exceed calorie limits on comparable National
School Lunch Program (NSLP) items.
4. Snack items meet a sodium content limit of 200 mg or less per portion
as packaged or 480 mg or less per entrée portion as served à la carte.
Standards for Nonnutritive Food Components
5. Beverages containing nonnutritive sweeteners are only allowed in

high schools after the end of the school day.
6. Foods and beverages are caffeine-free, with the exception of trace
amounts of naturally occurring caffeine-related substances.
Standards for the School Day
7. Foods and beverages offered during the school day are limited to
those in Tier 1.
8. Plain, potable water is available throughout the school day at no cost
to students.
9. Sport drinks are not available in the school setting except when
provided by the school for student athletes participating in sport
programs involving vigorous activity of more than 1 hour’s duration.
10. Foods and beverages are not used as rewards or discipline for
academic performance or behavior.
11. Minimize marketing of Tier 2 snacks, foods, and beverages in the
high school setting by locating Tier 2 food and beverage distribution
in low student traffic areas and ensuring that the exteriors of vending
machines do not depict commercial products or logos or suggest that
consumption of vended items conveys health or social benefit.
Standards for the After-School Setting
12. Tier 1 snack items are allowed after school for student activities for
elementary and middle schools. Tier 1 and 2 snacks are allowed after
school for high school.
13. For on-campus fundraising activities during the school day, Tier 1
foods and beverages are allowed for elementary, middle, and high
schools. Tier 2 foods and beverages are allowed for high schools after
school. For evening and community activities that include adults, Tier
1 and 2 foods and beverages are encouraged.
Definitions
Tier 1 foods and beverages for all students. Tier 1 foods are fruits,
vegetables, whole grains, and related combination products, and nonfat and
low-fat dairy products that are limited to 200 calories per portion as
packaged and 35% of total calories from fat, <10% of total calories from
saturated fats, zero trans fat ( 0.5 g per serving), 35% of calories from total
sugars, and 200 mg sodium. À la carte entrée items meet fat and sugar
limits as listed above.
Tier 1 beverages are water without flavoring, additives, or carbonation;
low-fat and nonfat milk in 8-oz portions, including lactose-free and soy
beverages and flavored milk with no more than 22 g of total sugars per 8-oz
portion; 100% fruit juice in 4-oz portions as packaged for elementary/
middle school and 8-oz portions for high school; and caffeine-free, with the
exception of trace amounts of naturally occurring caffeine substances.
Tier 2 foods and beverages are any foods or beverages for high school
students after school. Tier 2 snack foods are those that do not exceed 200
calories per portion as packaged and 35% of total calories from fat, <10%
of total calories from saturated fats, zero trans fat ( 0.5 g per serving), 35%
calories from total sugars, and a sodium content of 200 mg per portion as
packaged. Tier 2 beverages are noncaffeinated, nonfortified beverages with
<5 calories per portion as packaged, with or without nonnutritive
sweeteners, carbonation, or flavoring.
METHODS
Several sources were used to identify state laws, regulations, and policies
enacted prior to October 1, 2010, that govern the availability of competitive
foods and beverages in schools. These sources included the official state
government Web sites for all 50 states, the National Association of State
Boards of Education’s Health Policies database, and the National Conference
of State Legislatures’ Childhood Obesity database. Thirty-nine states have
such laws, regulations, or policies, and copies of relevant state policy
documents were obtained, including codified laws, state board of education
policies, memos, and resolutions for analysis. Eleven states did not have any
laws, regulations, or policies related to competitive foods in schools. For this
report, the word policy is used as an umbrella term encompassing a state law,
regulation, or state board of education policy.
To guide the analysis, CDC researchers developed and piloted a codebook

based on the IOM Standards. Each of the 13 IOM Standards was divided into
variables to reflect the complexity of the standard. For example, IOM Standard
1 is divided into 3 variables, and IOM Standard 7 is divided into 11 variables.
This process weighted Standard 7 more heavily than the others because it
encompasses the majority of standards related to the nutritional quality of
competitive foods. The process resulted in 33 variables; 28 were applicable for
elementary and middle schools, and 32 were applicable for high schools
(Appendix A).
Each of the variables was defined and coded based on the following general
rating system, similar to the coding methodology used elsewhere:[10]
0 = Variable not mentioned in state policy or is not required.

1 = Variable is mentioned in the state policy, but only partially meets the
variable definition or does not apply to entire school campus or entire school
day, or only a certain percentage of foods or beverages are required to meet
the variable definition.
2 = Variable is mentioned and fully meets or exceeds the variable
definition and applies to the entire school campus and the entire school day, or
competitive foods are banned.
For example, when coding a policy for the calories variable that snack
items must contain 200 calories or less per portion as packaged, the policy
would receive a “1” rating if it mentions lowering calories for snacks but does
not include a specific calorie level or only sets portion size limits for certain
snack foods. For this same variable, a state policy would receive a “2” rating if
it requires all snacks available on the school campus to be limited to 200
calories or less per portion as packaged.
CDC researchers independently reviewed and coded the state policy
documents for the 33 variables separately for each grade level—elementary,
middle, and high school (if applicable). Differences in coding were resolved
through discussion and consensus between the CDC researchers or by another
subject matter expert.
State policies were analyzed to determine how closely they align with
IOM Standards. Overall alignment scores were determined for each state
policy, across all school levels combined, and at each of the three different
school levels separately. Alignment scores were calculated by adding the sum
of scores for each applicable variable, dividing by the maximum possible score
(i.e., 176 across all school levels, 56 at the elementary and middle school
levels, and 64 at the high school level), and multiplying by 100 for ease of
interpretation.
A similar analysis looked only at the variables derived from the first 9
IOM Standards because they specifically address the nutrient content of foods
and beverages available during the school day. The maximum alignment
scores for the nutrient standards only analysis were calculated by adding the
sum of scores for each applicable variable, dividing by the maximum possible
score, (i.e., 140 across all school levels, 46 at the elementary and middle
school levels, and 48 at the high school level) and multiplying by 100 for ease
of interpretation.
State policy alignment scores were then categorized into quartiles (see
below). For both analyses, the higher the score and corresponding quartile, the
greater the alignment with IOM Standards.
Quartile 1 0–25.0
Quartile 2 25.1–50.0
Quartile 3 50.1–75.0
Quartile 4 75.1–100.0
In addition, each state policy’s alignment score is accompanied by the

number of IOM Standards that are met in the policy, either fully or partially—
identified as the scope of the state policy. To fully meet an IOM Standard, a
state policy had to score a “2” (the maximum score) for all applicable
variables at each school level. To partially meet an IOM Standard, a state
policy had to score a “1” on any of the applicable variables at any grade level.
The more IOM Standards that were fully or partially met, the greater the scope
of the state policy.
KEY FINDINGS
Description of State Policies
• As of October 1, 2010, 78% of the nation (39 states) had enacted state
policies for competitive foods in schools. Specifically,
− 27 states had policies that require schools to implement nutrition
standards for competitive foods and beverages. In Connecticut,
standards for beverages are required, but competitive food

standards are voluntary.
− 2 states (Massachusetts and Virginia) had recently enacted
legislation to develop state nutrition requirements for competitive
foods in schools, but no standards existed as of October 1, 2010.
− 4 states (Michigan, Pennsylvania, Utah, and Vermont) had policies
that recommend but do not require schools to implement nutrition
standards for competitive foods.
− 6 states (Delaware, Georgia, Maine, Maryland, New York, and
Oklahoma) had policies that only restrict the time and place of the
sale of FMNV at certain school levels that go beyond current
federal regulations for FMNV.
• 23 states had policies that were enacted before 2007, when the IOM
Standards report was released.
• 33 states had policies that include standards for each of the 3 school
levels (elementary, middle, and high school).
• 4 states (Arizona, Illinois, Oklahoma, and Tennessee) had policies
that apply only to the elementary and middle school levels.
• 2 states (Georgia and South Carolina) had policies that apply only to
elementary schools.
• 2 states (Indiana and North Carolina) banned vending machines in
elementary schools.
• 2 states (Arkansas and Florida) banned all competitive foods and
beverages in elementary schools throughout the entire school day and
campus.
• 2 states (Colorado and Connecticut) had policies for beverages only.
ALIGMENT OF STATE POLICIES WITH IOM STANDARDS

Overall Alignment Scores
No state policy fully met all of the IOM Standards (all 33 variables
assessed). Therefore, no state policy had alignment scores in the 4th quartile
(Figure 1). The majority of state policies had alignment scores in the 1st or
2nd quartile.
• 2 states (Hawaii and West Virginia) had alignment scores in the 3rd
quartile.
• 18 state policies had alignment scores in the 2nd quartile.
• 19 state policies had alignment scores in the 1st quartile.
Table 1 (see page 10) shows each state’s overall alignment score for all
schools levels combined and for each school level separately.
Figure 1. Alignment of State Policies for Competitive Foods and Beverages in Schools
with IOM Standards, All IOM Standards (N = 39 States).
Overall Alignment Scores by School Level
In most states, policies for competitive foods in middle and high schools
had lower alignment scores than those for elementary schools (Table 1 and
Figure 2). Although most state policies for elementary schools required 100%
of foods and beverages to meet state standards, some state policies for middle
and high schools only required a certain percentage (e.g., 50%) of foods or
beverages to meet state standards, resulting in a lower alignment score.
As Figure 2 illustrates, 4 states (Hawaii, Iowa, Mississippi, and West
Virginia) had policies for elementary schools in the 3rd quartile, compared
with only 2 states (Hawaii and West Virginia) in the 3rd quartile for middle
and high school levels. Arkansas and Florida were the only states with policies
for elementary schools in the 4th quartile. Both of these states banned all
competitive foods and beverages in elementary schools.
Figure 2. Number and Alignment Score of State Policies for Competitive Foods in
Each Quartile, All IOM Standards, by School Level (N = 39 States).
Alignment Scores of Food and Beverage Nutrient Standards

by School Level
Table 1 provides the alignment score for each state in meeting the 24
variables that make up the nutrient standards subset (IOM Standards 1–9) for
all school levels combined and separately for each school level. In this subset
analysis, all school levels combined, 1 state policy (Hawaii) had an alignment
score in the 4th quartile. Five states (Alabama, Arkansas, Iowa, Mississippi,
and West Virginia) had policies with alignment scores in the 3rd quartile, 20
states had policies with alignment scores in the 2nd quartile, and 14 states had
policies with alignment scores in the 1st quartile, indicating the least alignment
with IOM Standards.
Figure 3 shows the number of state policies in each quartile for this subset
of standards by school level. State policy provisions for food and beverage
nutrient standards were more aligned with IOM Standards at the elementary
school level than middle and high school levels. Seven states had alignment
scores for elementary school in the 3rd quartile, compared with 5 states for
middle school, and 2 states for high school. Arkansas, Florida, and Hawaii’s
alignment scores for elementary school were in the 4th quartile, indicating the
greatest alignment with IOM Standards. For this subset analysis, Hawaii was
the only state whose policy was in the 4th quartile (greatest alignment with
IOM Standards) for each grade level.
Figure 3. Number and Alignment Score of State Policies for Competitive Foods in
Schools in Each Quartile, by School Level, Nutrient Standards Only (Standards 1–9),
(N = 39 States).
Scope of State Policies
The scope of each state’s policies is a reflection of policy content (i.e.,

how many IOM Standards, fully or partially met, are included in a policy). The
larger the number of IOM Standards that are fully or partially met, the greater
the scope of the state policy. Table 1 provides details about the scope of each
state policy. In summary,
• The scope of state policies ranged from 0–12 out of 13 IOM

Standards.
• Table 1 shows that states can have lower alignment scores with a
broad scope. For example, Tennessee’s overall alignment score is
31.1 (out of 100, 2nd quartile), but its policy addresses 11 out of the
13 IOM Standards (a broad scope).
• The 5 states with the broadest scope were West Virginia (12
standards), Hawaii (11 standards), Tennessee (10 standards),
Arkansas (10 standards), Iowa (9 standards), Arizona (9 standards),
and Alabama (9 standards).
• The 2 states with the greatest alignment with IOM Standards (all IOM
Standards) also had a broad scope: West Virginia (12 standards) and
Hawaii (11 standards).
• Of the states with lower alignment scores (i.e. in the 1st quartile [N =
19]), 14 states partially met 1–8 of the 13 IOM Standards. The
remaining 5 states did not meet or partially meet any IOM Standards
because the standards in the state policies are not required or had not
been developed at the time of analysis.
Table 1. Alignment Score by School Level and Scope of State Policies for
Competitive Foods and Beverages in U.S. Schools
Alignment Scores of State Policies with IOM Standards

Nutrient Standards Only
Overall Scorea (out of 100) Scoreb (out of 100) Scope of State Policies
No. of No. of
IOM IOM
Standar Standards
All All ds Fully Partially
School School Met (out Met Total
State Levels E M H Levels E M H of 13) (out of 13) Scope
Alabama 43.2 48.2 46.4 35.9 51.4 56.5 54.3 43.8 0 9 9
Alaskac
Arizona 27.3 44.6 41.1 0 32.9 52.2 47.8 0 0 9 9
Arkansas 46.6 85.7 30.4 26.6 51.4 95.7 30.4 29.2 1 9 10
California 41.5 48.2 39.3 37.5 47.1 54.3 43.5 43.8 1 7 8
Colorado 23.3 26.8 26.8 17.2 24.3 28.3 28.3 16.7 0 6 6
Connecticutd 29.5 30.4 30.4 28.1 35.0 34.8 34.8 35.4 1 7 8
Delawaree 1.7 1.8 1.8 1.6 2.1 2.2 2.2 2.1 0 1 1
Florida 27.3 78.6 3.6 3.1 34.3 95.7 4.3 4.2 0 8 8
Georgiae 1.1 3.6 0 0 1.4 4.3 0 0 0 1 1
Hawaii 70.5 71.4 71.4 68.8 76.4 76.1 76.1 77.1 5 6 11
Idahoc
Illinois 26.1 41.1 41.1 0 31.4 47.8 47.8 0 0 6 6
Indiana 21.6 25.0 21.4 18.8 25.0 28.3 23.9 22.9 0 8 8
Iowa 47.7 55.4 46.4 42.2 57.9 65.2 54.3 54.2 3 6 9
Kansas 21.0 25.0 25.0 14.1 24.3 28.3 28.3 16.7 0 6 6
Kentucky 30.7 32.1 32.1 28.1 36.4 37.0 37.0 35.4 1 6 7
Louisiana 22.7 32.1 19.6 17.2 28.6 39.1 23.9 22.9 0 6 6
Mainee 8.0 7.1 7.1 9.4 8.6 8.7 8.7 8.3 0 1 1
Marylande 3.4 3.6 3.6 3.1 4.3 4.3 4.3 4.2 0 4 4
Massa
8.5 8.9 8.9 7.8 10.7 10.9 10.9 10.4 0 2 2
chusettsf
Michigand 0 0 0 0 0 0 0 0 0 0 0
Minnesotac
Mississippi 46.6 51.8 48.2 40.6 53.6 58.7 54.3 47.9 0 7 7
Missouric
Montanac
Nebraskac
Nevada 30.1 33.9 30.4 26.6 33.6 37.0 32.6 31.3 0 8 8
Alignment Scores of State Policies with IOM Standards

Nutrient Standards Only
Overall Scorea (out of 100) Scoreb (out of 100) Scope of State Policies
No. of No. of
IOM IOM
Standar Standards
All All ds Fully Partially
School School Met (out Met Total
State Levels E M H Levels E M H of 13) (out of 13) Scope
New Hamp-shirec
New Jersey 25.6 30.4 25.0 21.9 27.9 32.6 26.1 25.0 0 6 6
New Mexico 40.3 44.6 42.9 34.4 45.7 50.0 47.8 39.6 0 8 8
NewYorke 3.4 3.6 3.6 3.1 4.3 4.3 4.3 4.2 0 1 1
North 22.2 39.3 16.1 12.5 27.1 45.7 19.6 16.7 0 6 6
Carolina
NorthDakotac
Ohio 23.3 25.0 25.0 20.3 24.3 26.1 26.1 20.8 0 5 5
Oklahomae 4.5 7.1 7.1 0 5.7 8.7 8.7 0 0 1 1
Oregon 41.5 44.6 44.6 35.9 47.1 50.0 50.0 41.7 1 6 7
Pennsylvaniad 0 0 0 0 0 0 0 0 0 0 0
RhodeIsland 40.3 41.1 41.1 39.1 47.9 47.8 47.8 47.9 1 5 6
South 11.4 35.7 0 0 14.3 43.5 0 0 0 5 5
Carolina
South Dakotac
Tennessee 30.7 48.2 48.2 0 35.7 54.3 54.3 0 0 10 10
Texas 29.5 35.7 28.6 25.0 37.1 43.5 34.8 33.3 1 5 6
Utahd 0 0 0 0 0 0 0 0 0 0 0
Vermontd 0 0 0 0 0 0 0 0 0 0 0
Virginiaf 0 0 0 0 0 0 0 0 0 0 0
Washington 33.0 33.9 33.9 31.3 38.6 39.1 39.1 37.5 0 4 4
WestVirginia 60.2 62.5 62.5 56.3 62.1 65.2 65.2 56.3 6 6 12
Wisconsinc
Wyomingc
STATEMEDI 25.6 32.1 25.0 17.2 28.6 37.0 28.3 16.7
AN
Range 0–70.5 0– 0– 0– 0– 0– 0– 0–
71.4 71.4 68.8 76.4 80.4 76.1 77.1
E = elementary school, M = middle school, H = high school.
a
Overall alignment score is based on the sum of all variables for each applicable grade
level, divided by 176 points (the maximum possible score), multiplied by 100 for
ease of interpretation. Score for each grade level is based on the sum of applicable
variables for each grade level, divided by the maximum possible score for each
grade level (E = 56, M = 56, H = 64), multiplied by 100 for ease of interpretation.
b
Nutrient standards only alignment score is based on the sum of 24 variables for each
applicable grade level, divided by 140 points (the maximum possible score),
multiplied by 100 for ease of interpretation. Score for each grade level is based on
the sum of applicable variables for each grade level, divided by the maximum
possible score for each grade level (E = 46, M = 46, H = 48), multiplied by 100
for ease of interpretation.
c
No state policy for competitive foods.
d
Michigan, Pennsylvania, Utah, and Vermont have state policies for competitive
foods, but these policies are voluntary or only recommended for school districts to
implement. Connecticut’s competitive beverage standards are required, but
competitive food standards are voluntary.
e
State policy for competitive foods only has exemptions for foods of minimal
nutritional value (FMNV ). Maine has additional restrictions on competitive
foods, but these are not clearly defined.
f
Massachusetts and Virginia enacted legislation requiring their state education/health
agencies to develop state nutrition standards for competitive foods in schools.
These standards were not available at the time of this analysis. Massachusetts’
policy requires several elements to be included in the state standards. Two of these
elements relate to nutrition standards—the availability of water at no cost and the
availability of fruits and vegetables. These elements were coded.
A CLOSER LOOK AT EACH INSTITUTE

OF MEDICINE STANDARD
The IOM Standards that were most commonly met in state policies, either
fully or partially (across all grade levels combined), were as follows (see Figure
4):
• Standard 7: Tier 1 Foods (34 states).

• Standard 1: Dietary Fat (25 states).
• Standard 2: Total Sugars (25 states).
• Standard 9: Sport Drinks (24 states).
• Standard 13: Fund-raising (21 states).
• Standard 3: Calories (21 states).
The IOM Standards that were least commonly met in state policies, either
fully or partially, were as follows (see Figure 4):
• Standard 10: Reward or Discipline (3 states).

• Standard 11: Marketing (3 states).
• Standard 5: Nonnutritive Sweeteners (10 states).
• Standard 6: Caffeine (10 states).
• Standard 4: Sodium (10 states).

• Standard 12: After School (10 states).
• Standard 8: Water (13 states).
Only four of the IOM Standards were fully met by more than one state
policy:
• Standard 9: Sports Drinks (7 states).

• Standard 1: Dietary Fat (4 states).
• Standard 2: Total Sugars (3 states).
• Standard 3: Calories (2 states).
Figure 4. Number of States that Fully Met, Partially Met, or Did Not Meet Each
Institute of Medicine Standard.
DISCUSSION
Many schools and school districts have improved the nutritional quality of
competitive foods and beverages during the past decade. However, studies
have found room for improvement.[12–14] Competitive foods have the
potential to undermine the effect of federally reimbursable school meal
programs and may contribute to the increasing problem of childhood obesity
because these foods tend to be caloriedense.[15] In addition, school officials
and others are concerned that offering healthier options for competitive foods
and beverages, or not selling any competitive foods, will result in a loss of
revenue from the sale of these foods and beverages. Although some schools
report an initial decrease in revenue after implementing stronger nutrition
standards, a growing body of evidence suggests that schools can have strong
nutrition standards and maintain financial stability.[9,16,17]
Given the amount of time that children spend in school, the school
environment can greatly influence students’ attitudes, preferences, and
behaviors towards healthy eating. Studies have reported that when school-aged
children eat and drink foods and beverages high in fat, salt, and sugar, it can
displace their consumption of healthier foods (e.g., fruits, vegetables) and
beverages (e.g., low-fat or nonfat milk).[5,6] Schools play a critical role by
providing opportunities for young people to be exposed to a variety of healthy
foods and beverages, helping students develop good eating habits, and
teaching them about the importance of healthy eating. The development of
good eating habits at an early age should be encouraged because it can have a
beneficial effect on children’s school performance and helps them maintain a
healthy lifestyle as adults.[18,19] However, students receive mixed messages
when foods and beverages sold in their schools do not align with the nutrition
education they receive, or when unhealthy foods are marketed to them in their
schools.
This analysis included state policies for competitive foods in schools,
required or voluntary. Policies for Michigan, Pennsylvania, Utah, and
Vermont had alignment scores in the 1st quartile, indicating lowest alignment
with IOM Standards because they were voluntary. States such as Delaware,
Georgia, Maine, Maryland, New York, and Oklahoma also had policies with
lower alignment scores because their policies only restricted FMNV beyond
the current federal regulations for some grade levels and did not have required
nutrition standards for other competitive foods and beverages.
In Massachusetts and Virginia, state officials enacted policies for
competitive foods in schools before October 1, 2010, but these standards were
still under development at the time of this analysis. As a result, the alignment
scores for these policies are in the 1st quartile (lowest alignment).
In addition to policy requirements, financial incentives are a promising
way to increase implementation of competitive food standards that may be
voluntary, as with Pennsylvania and Connecticut state policies. Pennsylvania
enacted legislation in 2007 that provides a supplemental reimbursement for
each breakfast and lunch served as part of the School Breakfast Program and
the National School Lunch Program, to schools that adopt, implement, or
exceed the Pennsylvania Department of Education’s voluntary nutrition
guidelines for foods and beverages available on campus.
Connecticut reimburses schools with an additional 10 cents per lunch if
they meet the state’s voluntary Healthy Food Certification program.
Connecticut’s state policy only requires school districts to meet beverage
standards.
The results of this analysis show that state policies for competitive foods
and beverages in schools vary in their alignment with IOM Standards and the
scope of their standards. Overall, the majority of state policies have alignment
scores that are in the 1st and 2nd quartiles (i.e., below the 50th percentile).
Although some state policies incorporate elements of the IOM Standards for
competitive foods and beverages, no state fully met half (7 or more) of the 13
IOM Standards for all school levels. Overall, state policies for middle and high
schools were less aligned with IOM Standards compared with policies for
elementary schools. This finding is mirrored at the local/district level.[13,14]
This analysis has several potential limitations. The study examines the
language in codified laws and state board of education policies, memos, and
resolutions, not the actual implementation or compliance with a policy or other
actions at the district or school level to improve the quality of competitive
foods in schools. Secondly, researchers relied on government Web sites to
obtain codified laws and state board of education policy documents, some of
which may not be completely up-to-date.
The IOM Standards released in 2007 were used as the gold standard for
coding and analyzing state policies. Some states that enacted policies before
2007 might have been at a disadvantage compared with other states because
the information on the recommended standards was not available at the time
they adopted their policies. In addition, although state policies received
separate alignment scores for each school level, they did not receive separate
scores for different venues (e.g., vending machines, school stores, à la carte
food items). Examining policy alignment by venue could provide states with
additional and more specific information on how to improve their alignment

with IOM Standards.
A further limitation is that all IOM Standards were not given equal
weight. Standards were divided into variables depending on their complexity.
For example, IOM Standard 7 was divided into 11 variables, whereas Standard
1 was only divided into 3 variables, allowing Standard 7 to add greater weight
to the overall alignment score. Although the IOM did not rank the 13 standards
in order of importance, Standard 7 was given more weight because it
encompasses IOM Standards 1–6 and 9.
IMPLICATIONS FOR PRACTICE

The Healthy, Hunger-Free Kids Act of 2010 authorizes the U.S.
Department of Agriculture to develop federal standards for competitive foods
in schools that align with the most up-to-date science. The results of this study
can be used to aid the development of these new federal standards and to
provide technical assistance to states.
The federal government and states can use this information to identify
differences across grade levels and competitive food and beverage standards
that are less likely to be included in state policies, such as the standards on
sodium and water.
All states can demonstrate leadership by developing state policies that
align with IOM Standards for foods and beverages sold outside the school
meals program.
APPENDIX A. INSTITUTE OF MEDICINE (IOM)

STANDARDS AND RELATED VARIABLES
IOM Standards Variables Ea Ma Ha
(max (max (max
score) score) score)
Standard 1 1. 2 2 2
Snacks,foods,andbeverages Snacks,foods,andbeveragesprovide≤35%t
meet criteria for dietary fat otalcaloriesfromfatperportionaspackaged.b
per portion packaged. 2. Snacks,foods,andbeveragesprovide < 2 2 2
10% total calories from saturated fat per
portion as packaged.b
3. Snacks,foods,and beverages contain 2 2 2
zero transfat per portion as packaged.b

(max (max (max
Standard 2 4. Snacks,foods,andbeveragesprovide ≤ 2 2 2
Snacks,foods,and beverages 35% calories from total sugars per portion
provide ≤35% calories from as packaged.b
total sugars per portion as
packaged.
Standard 3 5. Snack items contain ≤200 calories per 2 2 2
Snack items are ≤200 calories portion as packaged.b
per portion as packaged and 6. Àlacarteentrée items do not exceed 2 2 2
àlacarteentrée items do not calorie limits on comparable NSLP
exceed calorie limits on items.b
comparable NSLPcitems.
Standard 4 7. Snack items meet a sodium content 2 2 2
Snack items meet a sodium limit of ≤ 200mg per portion as
content limit of ≤200 mg per packaged.b
portion as packaged or ≤480 8. Àlacarteentrée items contain ≤ 480mg 2 2 2
mg per entrée portion as sodium per entrée portion as served.b
served for àlacarte.
Standard 5 Beverages 9. Beverages containing nonnutritive * * 2
containing non nutritive sweeteners are only allowed in high
sweeteners are only allowed schools after the end of the schoolday.b
in high schools after the end
of the schoold ay.
Standard 6 10. Foods and beverages are caffeine- 2 2 2
Food sand beverages are free.b
caffeine-free, with the
exception of trace amounts of
naturally occurring caffeine-
related substances.
Standard 7 11. Fruits and vegetables.b 2 2 2
Foods and beverages offered 12. Whole grains.b 2 2 2
during the school day are 13. Non fat or low-fat dairy products.b 2 2 2
limited toTier1d foods and 14. 100% fruit and vegetable juices 2 2 2
beverages. (E=4ozmax; M,H=8ozmax).b
15. Non fat or low-fat milk 2 2 2
(E,M,H=8ozmax).b
16. Flavored milk, max 22 g total 2 2 2
sugars/8oz (E,M,H = 8 oz max).b
17. Prohibits regular (sugar-sweetened) 2 2 2
soda.b
18. Prohibits other beverages (other than 2 2 2
soda and sport drinks) that contain added
caloric sweetener.b
19. Prohibits FMNVe all day throughout 2 2 2
school campus.b
20. Allows Tier1 foods only in addition to 2 2 2
meeting all other IOM nutrient standards.b
21. Allows Tier1 beverages only in 2 2 2
Appendix A. (Continued)

(max (max (max
addition to meeting all other IOM nutrient
standards.b
Standard 8 22. Requires the availability of water 2 2 2
Plain, potable water is (bottled, tap, or fountain) at no cost
available throughout the throughout the school day.b
school day at no cost to 23. Prohibits carbonated, fortified, and 2 2 2
students. flavored waters.b
Standard 9 24. Prohibits sports drinks in the school 2 2 2
Sports drinks are not available setting.b
in the school setting.
Standard 10 25. Prohibits foods and beverages from 2 2 2
Foods and beverages are not being used as rewards.
used as rewards or discipline 26. Prohibits foods and beverages from * * 2
for academic performance or being used as discipline.
behavior
Standard 11 27. Minimizes marketing by locating * * 2
Minimizes marketing of Tier2 foods and beverages in low student
Tier2f foods and beverages in traffic areas in highschool.
high school setting. 28. Minimizes marketing by ensuring 2 2 *
exterior of vending machines do not
depict commercial products or logos or
suggest that consumption of vended items
conveys a health or social benefit in
highschool.
Standard 12 29. Allows Tier1 snacks for after school 2 2 *
Tier1 snack items are allowed for student activities in elementary and
after school for student middle schools.
activities for elementary and 30. AllowsTier1and 2snacks after school * * 2
middle schools.Tier1and 2 in high school.
snacks are allowed after
school in highschool.
Standard 13 31. Allows sale of Tier1food sand 2 2 2
Foron-campus fund-raising beverages during on-campusfund-raising
activities during the school activities.
day, Tier1 foods and 32. Allows sale of Tier2 foodsand * * 2
beverages are allowed for beverages on campus after school in
elementary, middle, and highschool.
highschools.Tier2 foods and 33. Encourages sale of Tier1 and 2 2 2 2
beverages are allowed for foodsand beverages during evening and
high schools after school.For community events that include adults.
evening and community
activities that include
adults,Tier1and 2foods and
beverages are encouraged.
Totals

(max (max (max
Numberofvariablesby N=33 28 28 32
schoollevel. N=24b 23b 23b 24b
Total maximum score by school level. 56 56 64
46b 46b 48b
Total maximum score for all variables and all school levels combined. 176
140b
* Not applicable.
a
E = elementary school; M = middle school; H = high school.
b
Indicates variables included in the nutrient standards only analysis and related
maximum scores for each school level.
c
National School Lunch Program.
d
Tier 1 foods, which are for all students, are fruits, vegetables, whole grains, and
related combination products and nonfat and low-fat dairy products that are
limited to 200 calories per portion as packaged and 35% of total calories from fat,
<10% of total calories from saturated fats, zero trans fat ( 0.5 g per serving), 35%
of calories from total sugars, and 200 mg sodium. Àla carte entrée items meet the
same fat and sugar limits. Tier 1 beverages are water without flavoring, additives,
or carbonation; low-fat and nonfat milk in 8-oz portions, including lactose-free
and soy beverages and flavored milk with no more than 22 g of total sugars per 8-
oz portion; 100% fruit juice in 4-oz portions as packaged for elementary/middle
school and 8-oz portions for high school; and caffeine-free, with the exception of
trace amounts of naturally occurring caffeine substances.
e
Foods of minimal nutritional value.
f
Tier 2 foods and beverages are any foods or beverages for high school students after
school. Tier 2 snack foods are those that do not exceed 200 calories per portion as
packaged and 35% of total calories from fat, <10% of total calories from saturated
fats, zero trans fat ( 0.5 g per serving), 35% calories from total sugars, and a
sodium content of 200 mg per portion as packaged. Tier 2 beverages are
noncaffeinated, nonfortified beverages with <5 calories per portion as packaged,
with or without nonnutritive sweeteners, carbonation, or flavoring.
APPENDIX B. CITATIONS OF STATE POLICIES ANALYZED

State Policy Citations
Alabama Alabama Administrative Code 290-080-030-.03
Resolution on the Recommendations of the Committee to Review the State of Health of
America’s Youth with Particular Emphasis on Alabama’s Youth—July 12, 2005
adopted Resolution Adopting Beverage Standards for Vending Sales in Alabama Public
Schools— June 14, 2007 adopted State Board of Education Policy Memo, Nov 1 2001,
Log # FY02-3005 (food)
Appendix B. (Continued)

Alaska No policy
Arizona Arizona Revised Statutes § 15-242
Arkansas Arkansas Code Annotated § 20-7-135
California California Education Code §§ 49430-49436 California Code of Regulations Title 5 §§
15500, 15501, 15575-15578
Colorado Colorado Revised Statutes § 22-32-134.5 Colorado Revised Statutes § 22-32-136
Connecticut Connecticut General Statutes Chapter 169 §§10-215e and 10-215f Connecticut General
Statutes Chapter 170 §10-221q
Delaware Delaware Administrative Code Title 14 800 §852
Florida Florida Administrative Code 6A-7.0411
Georgia Georgia Rules and Regulations 160-5-6-.01
Hawaii Hawaii State Board of Education Policy #1110-6 Hawaii State Board of Education
Policy #6810 State of Hawaii Wellness Guidelines
Idaho No policy
Illinois Illinois Administrative Code Title 23 §305.15
Indiana Indiana Code §20-26-9-19
Iowa Iowa Administrative Code 281-58.10
Kansas Kansas Statutes §72-5128
Kansas Education Regulation 91-26-1
Kansas State Board of Education— May 10 2010 approved minutes
Kentucky Kentucky Administrative Regulations Title 702 §6.090 Kentucky Revised Statutes
§158.854
Louisiana Louisiana Administrative Code Title 28 Chapter XLIX §741 Louisiana Revised Statute
§17:197.1
Maine Maine Code of Rules 05-071-51
Maine Revised Statutes Title 20-A 6662
Maryland Maryland Education Code Annotated § 7-423
Maryland State Department of Education, Management and Operations Memo
MOM012
Massachusett
Massachusetts General Laws Chapter 111, §222
s
Michigan Michigan State Board of Education Minutes Oct 2010
Minnesota No policy
Mississippi Code Annotated § 37-13-134 and 137
Mississippi Mississippi State Board of Education Policy #2002 (Competitive Food), #4003
(Beverage Regulations), and #4004 (Snack Regulations)
Missouri No policy
Montana No policy
Nebraska No policy
Nevada State Board of Education Approved Minutes June 17–18, 2005 Nevada State
Nevada
Department of Education Statewide Wellness Policy
New
No policy
Hampshire
New Jersey New Jersey Administrative Code Title 2, 36-1.7 and 36-1.11

New
New Mexico Administrative Code §6.12.5 New Mexico Statutes Annotated §22-13-13.1
Mexico
New York New York Education Code §915
North North Carolina Administrative Code Title 16 6H.0104 North Carolina General Statutes
Carolina §115C-264.2
North
No policy
Dakota
Ohio Ohio Revised Code §§3313.814, 816, 817 Ohio Administrative Code §3301-91-09
Oklahoma Statutes Annotated §70-5-147 Oklahoma Administrative Code §210:10-3-
Oklahoma
111
Oregon Oregon Revised Statutes Chapter 336 §423 Oregon Administrative Rules 581-051-0100
Pennsylvani
Pennsylvania Public School Code §1337.1
a
Rhode
Rhode Island General Laws §§16-21-7 and 16-21-29
Island
South South Carolina Code of Laws §§59-10-310 and 59-10-330 South Carolina Code of
Carolina Regulations §43-168
South
No policy
Dakota
Tennessee Code Annotated §49-6-2307
Tennessee
Tennessee Rules and Regulations 0520-1-6.04
Texas Texas Administrative Code Title 4 §§26.1-26.9
Utah Utah Administrative Code 277-719
Vermont Vermont Act 203 Section 16
Virginia Virginia Administrative Code Title 8 §20-290-10
Washington Washington Revised Code §28A.210.365
West Virginia Code of State Rules §§126-86-1 to 126-86-16 West Virginia Code §18-2-
West
6a
Virginia
West Virginia State Board of Education Policy 4321.1
Wisconsin No policy
Wyoming No policy
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[16] Centers for Disease Control and Prevention. Implementing Strong
Nutrition Standards for Schools: Financial Implications. Atlanta: U.S.
Department of Health and Human Services; 2011. Available at
http://www.cdc.gov/healthyyouth/nutrition/pdf/financial_implications.
pdf.
[17] Wharton CM, Long M, Schwartz MB. Changing nutrition standards in
schools: the emerging impact on school revenue. Journal of School
Health 2008;78:245–251.
[18] Florence MD, Asbridge M, Veugelers PJ. Diet quality and academic
performance. Journal of School Health 2008;78:209–215.
[19] Story M, Nanney MS, Schwartz MB. Schools and obesity prevention:
creating school environments and policies to promote healthy eating and
physical activity. Milbank Quarterly 2009;87(1):71–100.
Chapter 4
SMART SNACKS IN SCHOOL: USDA’S ''ALL

FOODS SOLD IN SCHOOLS'' STANDARDS ∗
United States Department of Agriculture
USDA recently published practical, science-based nutrition standards for

snack foods and beverages sold to children at school during the school day.
The standards, required by the Healthy, Hunger-Free Kids Act of 2010, will
allow schools to offer healthier snack foods to children, while limiting junk
food. The health of today’s school environment continues to improve. Students
across the country are now offered healthier school lunches with more fruits,
vegetables and whole grains. The Smart Snacks in School standards will build
on those healthy advancements and ensure that kids are only offered tasty and
nutritious foods during the school day.
Smart Snacks in School also support efforts by school food service staff,
school administrators, teachers, parents and the school community, all working
hard to instill healthy habits in students.
NUTRITION STANDARDS FOR FOODS

• Any food sold in schools must:
∗
This is an edited, reformatted and augmented version of the United States Department of
Agriculture publication, dated June 2013.
142 United States Department of Agriculture
o Be a “whole grain-rich” grain product; or

o Have as the first ingredient a fruit, a vegetable, a dairy product, or
a protein food; or
o Be a combination food that contains at least 1/4 cup of fruit and/or
vegetable; or
o Contain 10% of the Daily Value (DV) of one of the nutrients of
public health concern in the 2010 Dietary Guidelines for
Americans (calcium, potassium, vitamin D, or dietary fiber).*
• Foods must also meet several nutrient requirements:

o Calorie limits:
− Snack items: ≤ 200 calories
− Entrée items: ≤ 350 calories
o Sodium limits:
− Snack items: ≤ 230 mg**
− Entrée items: ≤ 480 mg
o Fat limits:
− Total fat: ≤35% of calories
− Saturated fat: < 10% of calories
− Trans fat: zero grams
o Sugar limit:
− ° ≤ 35% of weight from total sugars in foods
*On July 1, 2016, foods may not qualify using the 10% DV criteria.
**On July 1, 2016, snack items must contain ≤ 200 mg sodium per item
NUTRITION STANDARDS FOR BEVERAGES

• All schools may sell:
o Plain water (with or without carbonation)
o Unflavored low fat milk
o Unflavored or flavored fat free milk and milk alternatives
permitted by NSLP/SBP
o 100% fruit or vegetable juice and
Smart Snacks in School. 143
o 100% fruit or vegetable juice diluted with water (with or without

carbonation), and no added sweeteners.
• Elementary schools may sell up to 8-ounce portions, while middle
schools and high schools may sell up to 12-ounce portions of milk and
juice. There is no portion size limit for plain water.
• Beyond this, the standards allow additional “no calorie” and “lower
calorie” beverage options for high school students.
o No more than 20-ounce portions of
o Calorie-free, flavored water (with or without carbonation); and
o Other flavored and/or carbonated beverages that are labeled to
contain < 5 calories per 8 fluid ounces or ≤ 10 calories per 20 fluid
ounces.
o No more than 12-ounce portions of
o Beverages with ≤ 40 calories per 8 fluid ounces, or ≤ 60 calories
per 12 fluid ounces.
OTHER REQUIREMENTS
• Fundraisers
o The sale of food items that meet nutrition requirements at
fundraisers are not limited in any way under the standards.
o The standards do not apply during non-school hours, on weekends
and at off-campus fundraising events.
o The standards provide a special exemption for infrequent
fundraisers that do not meet the nutrition standards. State agencies
may determine the frequency with which fundraising activities
take place that allow the sale of food and beverage items that do
not meet the nutrition standards.
• Accompaniments
o Accompaniments such as cream cheese, salad dressing and butter
must be included in the nutrient profile as part of the food item
sold.
o This helps control the amount of calories, fat, sugar and sodium
added to foods by accompaniments, which can be significant.
144 United States Department of Agriculture
Public Comment
USDA is seeking comments on these standards. The formal 120-day

comment period is open through October 28, 2013. We also want to continue
to receive feedback during implementation of the standards, so that we are
able to make any needed tweaks to the standards based on real-world
experience. Feedback from students, parents, school food staff, school
administrators, State agencies and other interested parties is critical to ensuring
successful standards.
To find the standards online, simply go to http://www.regulations.gov and
search by the docket number, which is FNS-2011-0019, or you may type in the
name of the rule “Nutrition Standards for All Foods Sold in School”.
Chapter 5
“SMART SNACKS IN SCHOOL” NUTRITION

STANDARDS INTERIM FINAL RULE
QUESTIONS AND ANSWERS ∗
• What Do the New “Smart Snacks in School” Nutrition Standards Do?
The new standards will allow schools to offer healthier snack foods for our
children, while limiting junk food served to students. Students will still be able
to buy snacks that meet common-sense standards for fat, saturated fat, sugar,
and sodium, while promoting products that have whole grains, low fat dairy,
fruits, vegetables or protein foods as their main ingredients.
It is important to note that USDA has no role in regulating foods brought
from home. The standards do not apply to any foods brought to school in
bagged lunches, or for birthday parties and special events, including after-
school bake sales and fundraisers.
• Why are these standards necessary?
Nearly one third of children in America are at risk for preventable diseases
like diabetes and heart disease due to being overweight or obese. If left
∗
This document was published by the U.S. Department of Agriculture, June 2013.
146 U.S. Department of Agriculture
unaddressed, health experts tell us that this generation may be the first to live
shorter lives than their parents.
Students across the country are now getting healthier school lunches with
more fruits and vegetables, whole grains, and low-fat dairy based on scientific
recommendations for nutrition. Yet for most teens and a growing percentage
of elementary students, items offered a la carte and in vending machines still
lack healthy options. Many students consume at least one snack food a day at
school.
Parents are working hard to ensure their children grow up healthy and
their efforts should not be undone when their kids go to school. Our children’s
ability to learn in the classroom and reach their fullest potential depends on
what we do right now to secure their future.
• How did USDA determine the new standards?
The comment period on the Smart Snacks in School proposed rule closed
on April 9, 2013. Since that time, a dedicated staff at USDA’s Food and
Nutrition Service thoughtfully reviewed the public input provided on the
proposal, feedback that is reflected in the standards. While USDA received
nearly 250,000 comments from parents, teachers, school food service
professionals, and the food and beverage industry, the vast majority were
statements of support for the standards and did not provide detailed input on
the substance of the rule. Of the comments received, approximately 2,200
were unique comments that offered feedback on specific provisions of the
proposed standards. Based on that feedback, the new “Smart Snacks in
School” standards carefully balance science-based nutrition standards with
practical and flexible solutions to promote healthier eating at school.
USDA solicited input from Federal child nutrition program stakeholders,
including nutrition and health professionals, parents, academia, industry,
interest groups, and the public, and reviewed expert recommendations from
sources such as the Institute of Medicine (IOM) Report and the Dietary
Guidelines for Americans.
We also conducted a broad review of nutrition standards developed by
other entities including the HealthierUS Schools Challenge standards; existing
State and local school nutrition standards for foods and beverages sold in
competition with school meals; and existing voluntary standards and
recommendations that have been developed by various organizations, such as
the National Alliance for Nutrition and Activity and the Alliance for a Healthier
Generation.
“Smart Snacks in School” Nutrition Standards ... 147
• Aren’t states, schools, and the food industry already doing a lot to
improve food in schools?
States, schools and the food industry have taken notable steps to improve
the whole school food environment. With bi-partisan support, Congress
required the Department to establish nutritional standards for all food sold at
schools, including vending machines and ala carte lines, under the Healthy,
Hunger-Free Kids Act (HHFKA) as a complement to the improved school
meal standards for breakfast and lunch. National polls also show nearly 80%
of Americans support better nutrition standards for all food sold in schools.
Additionally, leading research has shown that while improvements are
being made, policies vary widely from state to state and from school to school.
Setting a national baseline allows every student to enjoy the benefits of healthy
snack food choices at school while providing greater certainty for food and
beverage companies.
• What is the timeline for implementation of the new “Smart Snacks in

School” nutrition standards?
With respect to the new requirements, the rule allows for an entire school
year for schools, the food industry and other stakeholders to make the
necessary adjustments to the school food environment. USDA stands ready to
offer training and technical assistance as schools transition to the new
standards.
• How will the new standards impact school revenue?
At least 39 states currently have some kind of competitive foods standard

already in place. In addition, thousands of schools have already taken
voluntary steps to enact competitive food standards that meet or exceed those
released today. The new standards establish a consistent national baseline that
will allow every student to enjoy the benefits of healthy snack food choices
while providing greater certainty for food and beverage companies.
Many schools have implemented voluntary standards with little or no loss
of revenue, and some schools have reported an increase in revenue after
introducing healthier foods. For example, West Virginia requires schools to
offer healthier beverages and restrict certain foods and soda, yet the majority
of principals report little or no change in revenues from snack foods.
USDA will do all we can to simplify any necessary transition for schools,
offering training and technical assistance to States and schools to address
challenges as they arise.
Exact revenue dollar figures vary by individual states, school districts and
individual schools. But USDA’s review of the existing evidence on revenue
impacts indicates that on a national scale, any changes would most likely be
very minimal, in the range of one percent of total school food revenues.
• How will food and beverages options be impacted by the new

standards? What products will be in, and what products will be out?
First, it is important to note that the new standards do not apply to foods
brought to school in bagged lunches, or for activities such as birthday parties,
holidays, and other celebrations. The intent of the standards is not to limit
popular snack items, but instead to provide snack foods for students that are
healthier. For example, chips would still be allowed, in healthier versions such
as baked tortilla chips, reduced-fat corn chips, and baked potato chips.
Tens of thousands of schools are already moving in this direction through
voluntary initiatives like the Alliance for a Healthier Generation (AHG) and
USDA’s HealthierUS Schools Challenge. USDA used the AHG nutritional
baseline as a model in developing these new standards.
Additionally, research shows that industry is already adjusting to parents’
desire for healthier snack foods. Many products being sold in schools already
meet the new standards or are very close to these standards.
• How will the new standards affect fundraising by school groups?
According to USDA research, more than half of all schools currently do

not allow fundraisers that sell sweet or salty foods. Through the new standards,
state agencies, not the federal government, will have the flexibility to set a
reasonable threshold for the number of exempt occasional school-sponsored
fundraisers.
And while only a small amount of snack foods are sold by school groups,
USDA recognizes that revenues from school stores, vending machines and
occasional fundraisers can play an important role in supporting student clubs,
parent teacher organizations, and booster groups. That is why the new
standards offer a significant amount of flexibility on food items sold by these
groups:
“Smart Snacks in School” Nutrition Standards ... 149
− All foods that meet the standards could be sold during fundraisers
during school hours.
− The standards do not apply to items sold during non-school hours,
weekends or off-campus fundraising events, such as concessions
during sporting events and school plays.
• Do these standards prevent children from bringing cookies to school

on their birthday or special event?
USDA has no role in regulating foods brought from home. These

standards only affect foods that are sold on school campus during the school
day. Time honored traditions like treats for birthdays, or foods at an
afterschool sporting event, are not subject to these standards.
• My school/state has its own standards for snack foods sold in schools.
How will they be affected by what USDA is doing?
The new standards are the minimum requirements for schools. States and
schools that have stronger standards will be able to maintain their own
policies.
• How will the foods provided as part of the school meal, but sold
separately as a la carte items, be affected by these standards?
Based on extensive public comment and feedback from school food

service personnel, the new standards exempt individual entrée items offered as
part of lunch or breakfast from all competitive food standards when sold a la
carte the day of or the day after they are served as part of a reimbursable meal.
USDA anticipates that this approach, along with the recent changes to
school meals, will result in healthier menu items being offered in the a la carte
line than in the past. In addition, this exemption provides flexibility to schools
in planning a la carte sales and handling leftovers.
• Will these standards significantly affect the profitability of small

businesses that sell products in schools?
Most food companies have diverse product portfolios with healthy options
that do meet the new standards. USDA estimates the new standards’ impact on
the sales of food items would be very limited. The sale of snack food in
schools represents less than one percent of all food shipments from U.S. food
manufacturers. In addition, a normal school year consists of about 180 days,
which means that during more than half of the year, the child is not limited in
the purchase of any one company’s products. Again, the new standards do not
apply to any foods bought off-campus, after school hours or brought to school
in bagged lunches.
Chapter 6
NUTRITION STANDARDS FOR ALL FOODS

SOLD IN SCHOOL ∗
Food/Nutrient Standard Exemptions to the Standard

General Standard To be allowable, a competitive • Fresh fruits and vegetables
for Competitive FOOD item must: with no added ingredients
Food. except water are exempt
1) meet all of the proposed from all nutrient standards.
competitive food nutrient • Canned and frozen fruits
standards; and with no added ingredients
2) be a grain product that contains except water, or are packed
50% or more whole grains by in 100% juice, extra light
weight or have whole grains as syrup, or light syrup are
the first ingredient*; or exempt from all nutrient
3) have as the first ingredient* standards.
one of the non-grain main food • Canned vegetables with no
groups: fruits, vegetables, added ingredients except
dairy, or protein foods (meat, water or that contain a small
beans, poultry, seafood, eggs, amount of sugar for
nuts, seeds, etc.); or processing purposes to
4) be a combination food that maintain the quality and
contains at least 1/4 cup fruit structure of the vegetable are
and/or vegetable; or exempt from all nutrient
standards.
∗
This document was published by the U.S. Department of Agriculture, June 2013.
(Continued)

5) contain 10% of the Daily
Value (DV) of a nutrient of
public health concern (i.e.,
calcium, potassium, vitamin D,
or dietary fiber). Effective July
1, 2016 this criterion is
obsolete and may not be used
to qualify as a competitive
food.
*If water is the first ingredient, the

second ingredient must be one of
items 2, 3 or 4 above.
NSLP/SBP Entrée Any entrée item offered as part of
Items Sold A la the lunch program or the breakfast
Carte. program is exempt from all
competitive food standards if it is
sold as a competitive food on the
day of service or the day after
service in the lunch or breakfast
program.
Sugar-Free Sugar-free chewing gum is exempt
Chewing Gum from all competitive food standards.
Grain Items Acceptable grain items must include
50% or more whole grains by
weight, or have whole grains as the
first ingredient.
Total Fats Acceptable food items must have ≤ • Reduced fat cheese
35% calories from total fat as (including part-skim
served. mozzarella) is exempt from
the total fat standard.
• Nuts and seeds and nut/seed
butters are exempt from the
total fat standard.
• Products consisting of only
dried fruit with nuts and/or
seeds with no added
nutritive sweeteners or fats
are exempt from the total fat
standard.
Nutrition Standards for All Foods Sold in School 153

• Seafood with no added fat is
exempt from the total fat
standard.
Combination products are

not exempt and must meet
all the nutrient standards.
Saturated Fats Acceptable food items must have < • Reduced fat cheese
10% calories from saturated fat as (including part-skim
served. mozzarella) is exempt from
the saturated fat standard.
• Nuts and seeds and nut/seed
butters are exempt from the
saturated fat standard.
dried fruit with nuts and/or
seeds with no added
are exempt from the
saturated fat standard.
Combination products are not

exempt and must meet all the
nutrient standards.
Trans Fats Zero grams of trans fat as served (≤
0.5 g per portion).
Sugar Acceptable food items must have ≤ • Dried whole fruits or
35% of weight from total sugar as vegetables; dried whole fruit
served. or vegetable pieces; and
dehydrated fruits or
vegetables with no added
nutritive sweeteners are
exempt from the sugar
standard.
• Dried whole fruits, or pieces,
with nutritive sweeteners
that are required for
processing and/or
palatability purposes (i.e.,
cranberries, tart cherries, or
blueberries) are exempt from
the sugar standard.
(Continued)

exempt dried fruit with nuts
and/or seeds with no added
are exempt from the sugar
standard.
Sodium Snack items and side dishes sold a
la carte: ≤ 230 mg sodium per item
as served. Effective July 1, 2016
snack items and side dishes sold a la
carte must be: ≤200 mg sodium per
item as served, including any added
accompaniments.
Entrée items sold a la carte: ≤480
mg sodium per item as served,
including any added
accompaniments.
Calories Snack items and side dishes sold a • Entrée items served as an
la carte: ≤ 200 calories per item as NSLP or SBP entrée are
served, including any added exempt on the day of or day
accompaniments. after service in the program
Entrée items sold a la carte: ≤350 meal.
calories per item as served including
any added accompaniments.
Accompaniments Use of accompaniments is limited
when competitive food is sold to
students in school. The
accompaniment must be included in
the nutrient profile as part of the
food item served and meet all
proposed standards.
Caffeine Elementary and Middle School:
foods and beverages must be
caffeine-free with the exception of
trace amounts of naturally occurring
caffeine substances.
High School: foods and beverages
may contain caffeine.
Nutrition Standards for All Foods Sold in School 155

Beverages
Beverages Elementary School
• Plain water or plain carbonated

water (no size limit);
• Low fat milk, unflavored (≤8 fl
oz);
• Non fat milk, flavored or
unflavored (≤8 fl oz), including
nutritionally equivalent
• milk alternatives as permitted
by the
• school meal requirements;
• 100% fruit/vegetable juice (≤8
fl oz); and
• 100% fruit/vegetable juice
diluted with water (with or
without carbonation), and no
added sweeteners (≤8 fl oz).
Middle School

• Low-fat milk, unflavored (≤12
fl oz);
• Non-fat milk, flavored or
unflavored (≤12 fl oz),
including nutritionally
equivalent milk alternatives as
permitted by the school meal
requirements;
(≤12 fl oz); and
added sweeteners (≤12 fl oz).
High School

• Low-fat milk, unflavored (≤12
fl oz);
(Continued)

• Non-fat milk, flavored or
unflavored (≤12 fl oz),
including nutritionally
equivalent milk alternatives as
permitted by the school meal
requirements;
(≤12 fl oz);
added sweeteners (≤12 fl oz);
• Other flavored and/or
carbonated beverages (≤20 fl
oz) that are labeled to contain
≤5 calories per 8 fl oz, or ≤10
calories per 20 fl oz; and
• Other flavored and/or
carbonated beverages (≤12 fl
oz) that are labeled to contain
≤40 calories per 8 fl oz, or ≤60
calories per 12 fl oz.
INDEX
beneficial effect, 130

A benefits, 3, 29, 34, 87, 106, 147
body mass index, 137, 138, 139
academic performance, 118, 134, 139
Bureau of Indian Affairs, 103
access, 28, 43, 64, 67, 73, 74, 78, 110, 111
Butcher, 8, 34
additives, 12, 119, 135
administrators, ix, 82, 85, 98, 106, 112, 141,
144 C
adolescents, viii, 62, 115, 137, 138
adults, 9, 118, 130, 134 caffeine, 8, 12, 15, 42, 118, 119, 133, 135
advancements, ix, 141 calcium, 67, 138, 142
advocacy, 31 calorie, 11, 12, 15, 42, 117, 120, 133, 143
affluent districts, viii, 2, 3, 22, 24, 30, 34, case studies, 31
54, 55 cash, 67
age, 6, 41, 66, 130 CDC, 27, 34, 37, 61, 62, 71, 72, 96, 102,
agencies, 71, 97, 116, 128, 143, 144, 148 111, 113, 114, 116, 120
Alaska, 136 Census, 10, 39, 41
American Samoa, 103 CFR, 7, 35, 38, 138
apples, 68 challenges, 100, 148
athletes, 118 cheese, 143
attitudes, 130 Chicago, 34, 37, 138, 139
audit, 64 childhood, 5, 72, 130
authority(s), 11, 60, 61, 63, 101, 103, 111, children, vii, viii, ix, x, 1, 2, 4, 5, 8, 11, 22,
116 30, 32, 34, 41, 62, 63, 66, 69, 71, 100,
awareness, 113 113, 115, 130, 137, 138, 141, 145, 146,
149
clarity, 107
B classroom, ix, x, 96, 99, 115, 146
climate, 29
bake sales, ix, 5, 145
Code of Federal Regulations, 35
balanced budget, 87
coding, 120, 131
barriers, 31, 60, 66, 90, 94, 95, 96, 110
collaboration, 71, 72, 97
behaviors, viii, 34, 115, 130, 137, 138
158 Index
College Station, 37 Dietary Guidelines, 5, 27, 37, 39, 67, 76, 77,
commercial, 118, 134 142, 146
commodity, 47, 50, 51, 53 Dietary Guidelines for Americans, 5, 27, 37,
community, 66, 71, 72, 93, 94, 100, 113, 39, 67, 76, 77, 142, 146
118, 134 dietary intake, 13
community support, 71 directors, 60, 63, 65, 79, 80, 81, 84, 86, 87,
competition, 3, 22, 29, 37, 93, 146 91, 97, 103, 104, 107, 108, 109, 110, 113
complement, 147 diseases, ix, 145
complexity, 98, 120, 132 distribution, 23, 109, 118
compliance, viii, 9, 58, 59, 131 District of Columbia, 7, 41, 68, 103, 104
composition, 43, 44 draft, 101, 107
Conference Report, 72
congress, 4, 8, 37, 72, 111, 113, 116, 147
consensus, 120 E
Consolidated Appropriations Act, 72
Economic Research Service, 1, 15, 17, 18,
consulting, 94
19, 20, 23, 24, 25, 26, 27, 36, 37, 45, 47,
consumers, 29, 100
48, 50, 51, 53, 54, 55, 56, 57, 58
consumption, 7, 35, 72, 91, 118, 130, 134,
economies of scale, 33
138
education, 67, 71, 72, 96, 111, 113, 116,
containers, 31
119, 128, 130, 131
cost, 6, 33, 66, 67, 101, 102, 118, 128, 134
elementary school, viii, 2, 3, 7, 9, 15, 16,
Court of Appeals, 7, 68
18, 19, 20, 21, 22, 42, 54, 60, 64, 65, 73,
covering, 3, 6, 29, 31, 75, 112
74, 75, 78, 79, 81, 82, 83, 84, 105, 106,
crust, 31
107, 111, 112, 122, 123, 124, 127, 131,
135
D elementary students, ix, 3, 146
e-mail, 107, 108, 109
dances, 99 energy, 5, 7, 8, 14, 93
data collection, 106, 107 enforcement, 112
data set, 107 enrollment, 10
database, 119 environment(s), viii, ix, 3, 4, 11, 14, 17, 19,
decision makers, 102 20, 21, 29, 30, 32, 34, 65, 68, 69, 71, 72,
demographic characteristics, 12, 138 79, 81, 95, 97, 99, 100, 101, 102, 103,
Department of Agriculture, v, 1, 62, 102, 110, 115, 130, 137, 138, 139, 141, 147
141 equipment, 65, 87, 88
Department of Defense, 103 ethnicity, 21
Department of Education, 37, 71, 72, 96, evidence, 130, 148
103, 113, 131, 136
Department of Health and Human Services,
34, 37, 39, 61, 71, 139 F
diabetes, ix, 145
facilitators, 110
diet, 8, 11, 14, 138
families, 39, 71, 113
dietary fat, 117, 132
Farm Bill, 113
dietary fiber, 142
Index 159
fat, ix, 3, 5, 11, 12, 13, 14, 15, 29, 31, 42, grades, 9
43, 44, 62, 65, 67, 78, 91, 105, 111, 113, granola, 91
116, 117, 119, 130, 133, 135, 142, 143, grants, 113
145, 146, 148 guidance, 5, 10, 32, 34
federal government, 67, 68, 69, 71, 91, 100, guidelines, 33, 63, 72, 94, 116, 131
111, 132, 148 guiding principles, 44
federal mandate, 117, 138
Federal Register, 38, 138
federal regulations, viii, 59, 63, 68, 74, 116, H
122, 130
Hawaii, 123, 124, 125, 126, 136
fiber, 5
health, ix, 31, 35, 62, 67, 69, 71, 72, 92, 93,
financial, 5, 6, 10, 25, 28, 29, 31, 32, 130,
94, 97, 102, 110, 113, 118, 128, 134,
131, 139
138, 141, 146
financial data, 10, 28
health education, 31
financial incentives, 131
health promotion, 31
financial stability, 130
heart disease, ix, 145
financial support, 25
HHS, 61, 71, 72, 96, 113
flexibility, 67, 148, 149
high school, 3, 8, 9, 11, 12, 15, 16, 28, 42,
fluid, 143
60, 64, 65, 73, 74, 75, 78, 79, 81, 82, 83,
food industry, 147
84, 85, 86, 87, 96, 99, 106, 118, 119,
food products, 34
120, 121, 122, 123, 124, 127, 131, 133,
food security, 6
134, 135, 143
food services, 65, 71, 84, 85, 86, 87, 88, 98,
House, 62
108, 112
House of Representatives, 62
foodservice, vii, viii, 1, 2, 3, 4, 5, 6, 7, 9, 10,
hypertension, 69
11, 14, 16, 17, 18, 19, 20, 21, 22, 25, 28,
30, 31, 32, 40, 41, 54, 55, 56, 57, 58
formation, 95 I
freedom, 11
fruits, ix, 3, 5, 12, 44, 62, 71, 91, 96, 113, ideal, viii, 115
117, 119, 128, 130, 135, 141, 145, 146 Impact Assessment, 36
funding, 9, 16, 33, 66, 67, 72, 90, 98 improvements, 13, 33, 72, 147
fundraisers, ix, 5, 16, 22, 40, 55, 56, 115, income, 3, 11, 29, 34, 111
143, 145, 148, 149 increased access, 78
fundraising, vii, 2, 16, 40, 118, 143, 148, Independence, 64, 91, 92, 94, 95, 97, 99,
149 109, 113
funds, 11, 16, 67, 72, 99, 100, 112 Indian reservation, 113
individuals, 60, 66, 81, 90, 93, 96, 101, 110
industry, 146, 148
G
ingredients, ix, 76, 77, 145
insecurity, 66
GAO, viii, 6, 7, 9, 39, 59, 60, 61, 69, 70, 71,
interest groups, 146
73, 74, 76, 77, 80, 82, 83, 85, 86, 88, 89,
Iowa, 41, 123, 124, 125, 126, 136
92, 106, 108, 110, 111, 112, 113, 138
iron, 67
Georgia, 41, 122, 130, 136
issues, 63, 92, 93, 96, 102, 103, 106
goods and services, 87
160 Index
nutrient(s), 5, 8, 14, 34, 43, 44, 67, 91, 121,

L 124, 133, 134, 135, 142, 143
lactose, 119, 135
laws, 119, 131 O
lead, 60, 66, 90
leadership, 93, 94, 132 obesity, vii, viii, 2, 5, 8, 35, 59, 62, 69, 72,
LEAF, 39 100, 115, 130, 139
Leahy, 62 obesity prevention, viii, 115, 139
legislation, 37, 63, 122, 128, 131 obstacles, 63, 65, 90
local government, 63 officials, 7, 60, 65, 66, 72, 79, 81, 82, 90,
Louisiana, 41, 126, 136 94, 95, 98, 100, 101, 103, 106, 107, 110,
112, 116, 130
Oklahoma, 41, 122, 130, 137
M operations, 6, 60, 65, 67, 83, 87, 98, 100,
101
majority, 5, 13, 20, 22, 27, 43, 60, 65, 68,
opportunities, ix, 115, 130
73, 79, 81, 83, 94, 103, 108, 120, 122,
overweight, ix, 62, 145
131, 146, 147
management, 3, 67
marketing, 31, 32, 33, 99, 118, 134 P
Maryland, 41, 122, 130, 136
mass, 137, 138, 139 parents, ix, 72, 93, 94, 96, 100, 141, 144,
materials, 71 146, 148
matter, 120 pediatrician, 93
MB, 139 percentile, 16, 17, 23, 131
median, 16, 17 physical activity, ix, 31, 40, 71, 72, 115, 139
medical, 93 physical education, 93, 110
Mercury, 38 pilot study, 33
messages, 130 PM, 137, 138
methodology, 10, 120 policy, 7, 22, 35, 40, 55, 56, 65, 72, 80, 81,
Mexico, 41, 127, 137 94, 95, 97, 99, 100, 119, 120, 121, 122,
Missouri, viii, 41, 60, 64, 109, 136 124, 125, 128, 129, 131, 136, 137
modifications, 35 population, 90, 103, 104, 108, 109
Montana, 41, 136 population size, 90
potassium, 142
potato, 44, 91, 148
N poverty, 20, 22, 24, 39, 41, 54, 55
preparation, 36, 67
National Academy of Sciences, 72
private schools, 28
National Center for Education Statistics, 10
probability, 104
National School Lunch Program, vii, ix, 2,
professionals, 71, 146
4, 7, 9, 12, 35, 36, 37, 38, 40, 58, 61, 63,
profit, 31
66, 103, 116, 117, 131, 135, 138
profitability, 149
needy, 99
project, 31
negative effects, 8
public health, 62, 69, 142
negative relation, 31
Index 161
public schools, 9, 28, 63, 103, 104, 111, 138 school meals, vii, viii, ix, 2, 4, 5, 9, 21, 30,
Puerto Rico, 104 59, 60, 66, 67, 68, 72, 87, 91, 98, 102,
purchasing power, 16 103, 110, 115, 116, 117, 132, 146, 149
school performance, 130
science, ix, 132, 141, 146
Q scope, 121, 125, 131
secondary school students, 2
quartile, 11, 17, 20, 21, 24, 25, 121, 122,
secondary schools, 7, 8, 16, 17, 19, 20, 21,
123, 124, 125, 126, 130, 131
22, 27, 32, 40, 55
questionnaire, 28, 40, 41, 42
secondary students, 3, 32
Senate, 62
R service provider, 111
services, 6, 60, 67, 71, 85, 86, 87, 99, 112,
race, 21 138
reactions, 110 shortfall, 87
recall, 45, 47, 48, 50, 51, 53 small businesses, 149
recognition, 113 society, 69
recommendations, ix, 72, 93, 100, 116, 146 socioeconomic status, 64, 90, 110
Reform, 62 sodium, ix, 3, 5, 12, 31, 44, 67, 116, 117,
regulations, 4, 5, 7, 30, 34, 68, 90, 101, 111, 119, 132, 133, 135, 142, 143, 145
116, 119, 144 South Dakota, 41, 127, 137
reimburse, 67 special education, 103
requirements, vii, 1, 9, 58, 67, 91, 97, 101, spending, 3, 22, 29
111, 116, 122, 131, 142, 143, 147, 149 stability, 31
researchers, 40, 43, 102, 120, 131 stakeholders, 146, 147
resources, 34, 71, 93, 97, 113 state(s), viii, 59, 63, 67, 68, 87, 90, 94, 96,
response, 40, 41, 69, 107, 110 97, 100, 103, 104, 111, 112, 113, 116,
restaurants, 96 119, 120, 121, 122, 123, 124, 125, 126,
restrictions, viii, 3, 15, 42, 59, 63, 68, 99, 128, 129, 130, 131, 132, 147, 148, 149
111, 112, 128 state laws, 116, 119
rewards, 89, 118, 134 state legislatures, 63
Richland, 64, 91, 94, 95, 97, 98, 110 stigma, 29
rights, 75 structure, 72
risk(s), ix, 29, 69, 98, 100, 145 student enrollment, 10
rules, 116 student populations, vii, 2, 29
style, 32
substitution, 30
S sweeteners, 44, 91, 118, 119, 133, 135, 143
safety, vii, 2, 72
sample design, 104 T
sampling error, 106
saturated fat, ix, 3, 5, 12, 67, 117, 119, 132, target, 7, 40, 103, 104
135, 145 target population, 103, 104
school community, ix, 141 teachers, ix, 65, 93, 100, 110, 141, 146
162 Index
technical assistance, 71, 72, 97, 100, 101, vegetables, ix, 3, 5, 8, 12, 13, 15, 44, 62, 71,
132, 147, 148 75, 91, 96, 113, 117, 119, 128, 130, 133,
technical comments, 101 135, 141, 145, 146
teens, ix, 146 vending machines, vii, ix, 2, 5, 9, 11, 16, 40,
telephone, 104 63, 64, 65, 66, 68, 73, 74, 75, 78, 79, 81,
testing, 94 91, 97, 98, 99, 105, 111, 112, 113, 115,
textbooks, 88 118, 122, 131, 134, 146, 147, 148
total revenue, 6, 23, 25, 56, 84, 87, 112 venue, viii, 65, 73, 79, 83, 108, 112, 115,
traditions, 149 131
training, 147, 148 vitamin D, 142
type 2 diabetes, 69 vitamins, 67
vocational education, 103
voting, 94
U
U.S. Centers for Disease Control and W

Prevention, 62
U.S. Department of Agriculture (USDA), v, wants and needs, 16
ix, 36, 37, 38, 39, 43, 61, 62, 101, 102, Washington, 41, 110, 111, 112, 113, 127,
116, 132, 145, 151 137, 138
United, v, 1, 35, 59, 62, 141 waste, 36
United States, v, 1, 35, 59, 62, 141 water, 8, 14, 15, 28, 30, 42, 43, 91, 99, 105,
urban, 3 118, 119, 128, 132, 134, 135, 142, 143
urbanization, 26 wealth, 10
USDA school meals, vii, 1, 2, 3, 4, 5, 7, 10, wellness, 8, 22, 25, 40, 55, 56, 58, 69, 72,
29, 30 96, 100, 101, 110, 116, 138
WIC, 8, 37, 61, 72, 110, 111, 113
Wisconsin, 35, 41, 137
V Women, Infants, and Children, 111
variables, 10, 40, 109, 120, 121, 122, 124,

127, 132, 135 Y
variations, 106
young people, 62, 130

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NUTRITION AND DIET RESEARCH PROGRESS

REVENUE ISSUES AND NUTRITION

Additional books in this series can be found on Nova’s website

Additional E-books in this series can be found on Nova’s website

REVENUE ISSUES AND NUTRITION

NOTICE TO THE READER

Independent verification should be sought for any data, advice or recommendations

Library of Congress Cataloging-in-Publication Data

ISBN:  (eBook)

Published by Nova Science Publishers, Inc. † New York

Across America, meals provided through USDA’s National School Lunch

School Food Authorities to examine competitive food selections and their

NUTRITION STANDARDS FOR COMPETITIVE

Joanne F. Guthrie, Constance Newman,

districts and served fewer students receiving free and reduced-price

A REPORT SUMMARY FROM THE ECONOMIC

What Is the Issue?

What Are the Findings?

Desserts, sweetened beverages, salty snacks, and candy made up more

associated revenue. In SFAs where competitive food revenues make up a

How Was the Study Conducted?

CONGRESS MANDATES UPDATE OF NUTRITION

the financial viability of school food-services (Rinaldi, 2008; Greves and

characteristics. Results should be useful to program and policy officials at

Since the beginning of the National School Lunch Program (NSLP) in

secondary schools (87 percent of middle schools; 98 percent of high schools

Nutritional Impacts of Competitive Foods

Competitive foods could have negative effects on children’s diets either

Policy Actions to Improve Competitive Foods

Competitive Food Revenues

School Food Authority Characteristics Survey (SFACS)

• Are National School Lunch Program

Our analysis of School Nutrition Dietary Assessment III (SNDA-III) data

Secondary-Level Students Consumed More Competitive Foods

One-third (33 percent) of elementary-level students consumed competitive

Competitive Food Revenues Vary across and within School

Table 1. Competitive food/beverage items selected by students, school

Total Percent of Percent of Percent of

Non-Foodservice Revenues From Competitive Foods

In many schools, principals, booster clubs, and other non-school

Revenues obtained from competitive food sales differ greatly between

At the secondary level, almost all school foodservices have some

Figure 1. Mean annual school foodservice competitive food revenues.

School Profiles: Characteristics by Food Revenue Quartile

We divided elementary and secondary schools into quartiles based on per-

Figure 3A. Socioeconomic and meal program characteristics of elementary schools in

Figure 3B. Socioeconomic and meal program characteristics of secondary schools in

Figure 4A. Nutrition environment characteristics of elementary schools in differing

Figure 4B. Nutrition environment characteristics of secondary schools in differing

Whether elementary or secondary, high competitive-revenue schools

• More affluent, with none of the high-revenue elementary and

averaged 44 percent participation, compared to 64 percent

Findings on ethnicity differed by school level. Elementary schools in the

School Nutrition Environment Characteristics

compared to the lowest revenue quartile, had higher percentages of schools

School Food Authorities (SFAs) with Higher Shares of Revenue

Using SFA-level data from the School Food Authority Characteristics

Figure 5. School Foodservice Authority (SFA) competitive food revenue as percent of

SFA Profiles: Characteristics Associated with Higher Shares of

To better understand what types of SFAs derived more revenue from

Figure 6. Composition of School Foodservice Authority (SFA) revenues in SFAs with

The SFACS was designed to be representative of FNS regions, allowing

Figure 7A. Socioeconomic characteristics of School Foodservice Authorities (SFAs) in

ISBN: (eBook)