DOC{lKENT RES{lKE 03052 - (A2133218]

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DOC{lKENT RES{lKE03052 - (A21332"18]summary of a Report: The National School Lunch Program, Is Itllorking? PAD-77-7: 5-111810. Jujy 26, 1977. 16 pp.Report to the Congress: hy Elmer B. Staats, Comptroller General.Issue Area: Income Security Programs: Program Effectiveness(1302): Prograll Evaluation Systems: Ne" Techniques andStandards (2602):Food: Domestic Food Assistance Programs(1707) Contact: Program Analysis Div.Budget Function: AgricUlture: Farm Income Stabilization (3511;Income Security: Public lssistance and Other IncomeSupplements (604): Health: Health Research and Education(552) Organization concerned: Department of AgricUlture: Department ofHealth, Education, and Welfare.Congressional Relevance: House Committee on Education and Labor:Senate Comllittee on Agriculture, Nutrition, and Forestry:Congress.Authority: National School Lunch Act of 1946 (P.L. 79-396).There are shortcomings in both the evaluation and theperformance of the School Lunch Program. Recommendations: TheSecretary of 19riculture should require a formal, systematicevaluation of the National School Lunch Prograll's performance iumeeting legislative objectives and shOUld deterlline thenutritional standards needed for the program. The Congressshould: require the Department of Health, Education, and llelfare(HEll) to assist the {I. S. Department of 19riculture ({lSDA). inevaluating the school lunch program's health impact on children;review {lSD1' 5 program evaluation plan before i rple mentation tomake certain that it will provide adequate information forprogram oversight, that it uses the resources and expertise of{lSDl and HEll in a manner that benefits the evaluation, and thatit is in keeping witb the respective missions of each agency:reguire the Secretary of 19riculture, On co.pletion of theschool luuch program evaluation, to provide a comprehensivereport of his findings, together "ith any recommendations he lIayhave with respect to improving program effectiveness: andprovide policy guidance indicating specifically what the goalsof the program should be and what the priorities are, and havethe program evaluated accordingly. (SC)

REPORT TO THE CONGRESS1/.J'BY THE COMPTROLLER GENERALOF THE UNITED STATESSummary Of A Report:The National SchoolLunch Program-Is It Working?Departments of Agriculture andHealth, Education, and WelfareThis is a summary of a report to the Congress(PAD·77·6) on the impact and effectivenessof the National School Lunch Program. Thereport identifies shortcomings in both theevaluation and performance of the SchoolLunch Program. It recommends specificac tions for improving the effectiveness andefficiency of program services.Areas discussed include··schoolchild health,--children in need of nutrition,--operating efficiency, and.relationship of the program to the Na·tion's agricultural economy.PAD·77·7JULY 26, 1977

COMPTPtOLLE" GENEftAL 0".' THE UNITED STATESWASHINGTON.c.e.lU4.B-111810TO the President of the Senate and theSpeaker of the House of RepresentativesThis report is a summary of our report to the Congress(PAO-77-6), "The National School Lunch Program--Is It Working?,"which is being released concurrently.Our review was made pursuant to the Budget and Accounting Act, 1921 (31 U.S.C. 53), the Accounting and AuditingAct of 1950 (31 U.S.C. 67), and the Legislative Reorganization Act of 1970 as amended by title VII of the CongressionalBudget Act of 1974 (31 U.S.C. 1154).Copies of the report are being sent to the Director,Office of Management and Budget; the Secretary of Agricul-",,' ""' ".,.,."" ., '·'1::.:'''4.' Comptroller Generalof the United States

PREPACEThis report summarizes the f ndings and recolMlendationspresented in our pr incipal report lPAD"77'-6-), "The NationalSchool Lunch- Pro9r m--Is-It Working?"The principal report focuses on what we beHeve-to bethe main issue in evaluating the school lunch program--itseffectiveness in meeting its -stilted legislative objectives(safeguarding health nd increa.ing foOd demand).

Con t e n t s PageINTRODUCTION1PROGRAM ISSUES2HEALTH IMPACT4AGENCY COMMENTS AND OUR EVALUATION8AGRICULTURAL CONSIDERATIONS10AGENCY COMMENTS AND OUR12 VALUATIONPARTICIPATION CONSIDERATICNS13AGENCY COMMENTS15OPERATING EFFICIENCY15AGENCY COMMENTS16

INTRODUCTIONThe National School Lunch Program (NSLP), authorized bythe National School Lunch Act of 1946 (Public Law 79-396) andexpanded in more recent legislation, is the largest of severalfederally funded child-feeding programs.As stated in the authorizing legislation, NSLP's objectives are n* * * to safeguard the health and wel1 being of theNation's children and to encourage the domestic consumptionof nutritious agricultural commodities and other food. * * *"TO do this, the Federal Government encourages ana·assistspublic and nonprofit private schools of high school grade andunaer to serve well-balanced lunches to children. This assistance includes:--A basic cash and donated food subsidy for all lunches,with additional cash reimbursement for meals servedfree or at reduced prices to children who cannot paythe full pr ice.--Nonfood assistance funds to help needy schoolsacquire food service equipment.--State administrative expense funds to partiallyreimburse States for undertaking the additionaladministrative activities required by the program.--Limited funds to undertake prograr.,-related nutr itiona1education and training projects, studies and surveysof food service requirements, and special developmentprojects.From 1947 to 1975 NSLP has increased in Federal expenditure from less than 100 million to more than 1.7 billiOn(cash and commodities). In fiscal year 1975 children's payment approximated 1.3 billion; State and local contributionsamounted to 850 million. In the same year, about 88,800schools (approximately 81 percent of the Nation's total)were members of NSLP, making program lunches available toalmost 88 percent of all schoolchildren. Over 25 millionchildren (56.7 percent of the NSLP enrollment) participatedin the program; nearly 39 percent of these children receivedfree or reduced-price lunches.Between 1946 and 1970, there was continuous growth in thesize of the U.S. schoolchild population. That trend peakedat 52.1 million students in 1970; and by 1975, school1

enrollment had declined by about 1.2 million students.The decline, associated with a drop in birth rates duringthe 1960s, has to date affected only elementary schoolenrollment.Current census projections indicate further declinesin school enrollment. Compared with 50.9 million studentsenrolled in 1975, the 1980 enrollment in'regular day schoolsis expected to be between 45 and 47 million.The continuing decline in U.S. enrollment and the current shift of students from elementary to secondary schools(where lunch program participation has traditionally beenlower) create downward pressures on NSLP participationlevels. Of course, many other factors, such as expandedprogram availability, changes in lunch prices, and improvements in the attractiveness of program lunches, may interactto change participation.In general, we believe that the basic program structureprovides an adequate framework for the large-scale feedingof schoolchildren. It appears, however, that there aresubstantial opportunities for improving the efficiency andeffectiveness of the program.PROGRAM ISSUESThough th program has been in operation for three decadesand many studies have been made, we did not find a comprehensive evaluation of the program's effectiveness in meeting itsstated legislative objectives. Though many of the reportscontain important information on program performance, theinformation generally has not been evaluated and assembledin a way to assist the Congress in apportioning scarce budget resources, in considering program revisions, and inoverseeing program administration. Four issues, which webelieve are the fundamental topics of an NSLP evaluation,have not been atisfactorily resolved.1. What is the program's impact on the participants?Does the program, nationally, safeguard children'shealth?2. What is the program's impact on the consumption ofagricultural commodities? Do children consume moreagricultural pr ducts under NSLP than if it did notexist? And how does the change in consumption, ifany, affect the Nation's agricultural economy?2

3. Is the program reaching the defined targetpopulation? To what extent are nutritionallyneedy children participating in NSLP and whatare the health conditions and dietary habits ofthose who do not participate?4. To what extent are the specified services provided?And, in relation to alternative ways of providingthese services, are program services provided inthe most cost-effective manner?The National School Lunch Act of 1946 established two major objectives: (I) to safeguard health through a program ofnutrition intervention and (2) to supplement farm income byincreasing food demand. Over the ensuing years, nationalpriorities changed, NSLP has become primarily for sed onone objective--safeguarding schoolchildren's hea Ln.To help meet this objective, legislation requires thatlunches served by schools participating in NSLP shall meetthe minimum nutritional requirements prescribed by theSecretary of Agriculture. The Secretary's requirements,however, have never been set forth as a simple nutritionalstandard per se (e.g., that a lunch should provide one-thirdof a participant's recommended dietary allowances (RDA)).Instead, they prescribe the use of a meal pattern requiringspecified quantities aHd groups of foods which, on the average, should provide one-third of a schoolchild's RDA. Thecurrent meal stanjard, the type A pattern, is composed of:--One-half pint of fluid milk. II--Two ounces (edible portion) of lean meat, poultry,or fish, an equivalent quantity of an alternatesuch as cheese, cooked dry beans or peas or peanutbutter, or an equivalent combination of any of these.--A three-fourths cup serving of two or more vegetablesor fruits (full strength fruit or vegetable juicesmay be counted as part of this requirement).--One slice of whole grain or enriched bread, or anacceptable equivalent. 21liThe definition of milk waS expanded in 1973 to include fluid- forms of whole, low-fat, skim, cultured buttermilk and flavored forms of these milks.2/In 1974, the definition of bread was expanded to include- crackers, taco shells, pizza crust, etc.3

--One teaspoon of butter or fortified margarine. (Thisrequirement was deleted from the pattern in June 1976.)This food-based pattern (developed in 1946) provides apractical means for insuring that all food service personnel,regardless of their training, can understand the program'snutritional requirements. The pattern also reflects thefact that, until recently, most schools prepared lunchesprimarily from raw ingredients.This lunch--as designed, served, and eaten--is, in ouropinion, one of the most crucial factors affecting programeffectiveness. The quantity and type of food included inthe lunch largely determine its cost and the amount ofagricultural commodities consumed. The price and presentation of the lunch determine how well the program reachesthe Nation's schoolchildren. And, the nutritional qualitiesof the lunch determine how well the program safeguardshealth.The type A pattern imposes definite limitations on theform and content of an NSLP lunch. Milk, for example, is mandatory whether or not juice is served; and two Or more vegetables or fruits must be included in the lunch. On the otherhand, one-third RDA can be provided in a variety of lunchstyles. As stated by Dr. Jean Mayer, Professor of Nutritionat the Harvard School of Public Health:"American eating habits have changed drasticallyin the last 20 years and today's typical lunchis not usually a fullsized meal. Peanut butteror ham and cheese on whole-grain bread, a glassof milk and fruit or a glass of orange juice, isa nutritious and well-balanced meal, and more inkeeping with today's eating habits. Food do ,siittle good unless it i eaten. And now, of alltimes, we can ill afford to waste either moneyor food. Perhaps we should begin to change theschool lunch program by trying to save food andmoney. We will be better able to feed everychild in need.1IHEALTH IMPACTAlthough studies sh w that the school lunch, when pairedwith a nutritional SUef ement or with the school'breakfast,can affect the nutdtlonal levels of schoolchildren, theirfindings about how the lunch itself affects either nutritionally deprived or nutritionally adequate participants are inconclusive. In Our opinion, the absence of any indicationthat the program is having a net beneficial impact on4

schoolchildren's health r"h:,es some questions about theeffectiveness of the nutr'itional aspects of the lunchitself. The type A lunch does appear to be effective insupporting the program's agricultural objective (increasing food intakes), but we ate not convinced that it represents the best available choice for a nutritional standard.In comparison with other types of lunch standards, thetype A lunch:--Appears relatively ineffective in achieving theprogram's nutritional objective. The lunch, asa standard meal served to all participants, doesnot appear to deal well with diverse nutritionalproblems. An alterna'tive meal standard--providingmore flexibility in the content and/or portionsizes--may improve the program's nutritionalimpact.--May increase the cost of program lunches (therebydiscouraging the participation of paying students).--Is often presented ir\ a form which d'iscouragesstudent participation and contributes to food waste.Nutrition, the lack or the excess or the quality of it,appears to be a problem for millions of the Nation's schoolchildren. The threat is not overt, as in deficiency diseasessuch as beriberi or scurvy. It is much more complex, oftenwithout visible signs, and usually associated with one ormore of the following:--Deficiencies in RDA nutriture, which may impairgrowth, development, and the ability to withstandinfectious diseases.--Excessive intakes of calories, which may contributeto the development of heart and allied diseases.--Poor choices in the nonnutrient part of diet, whichmay contr lbute' to the developr,lent of diseases suchas tooth decay and, in the opinion of some author ities--thOugh not yet accepted as scientific fact--maycontribute to hypertension and bowel cancer.While these problems indicate a need to place greateremphasis on the subject of nutrition education, it should berecognized that such actions are traditionally the prerogativeof St'ate and local governments. NSLP' s author izing5

legislation expressly prohibits the program from imposi gany requirement relative to the teaching of nutrition toschoolchildren. The proyram's health impact, therefore,is directly dependent on the benefits of eating a programlunch.In our opinion, the design of the NSLP lunch needs to bereassessed. Not only does the program's single meal patternappear "out-of-phase" with the needs of schoolchildren, italso has an inherent capability for producing und'esiredside effects.!1 Indications are that the current lunch--provides a valuable source of nourishment forsome children;--may contribute to obesity in others; and--is relatively ineffective in improving ironnutrlture (the most prevalent deficiency reportedfor schoolchildren).Despite annual subsidy outlayS in excess of Ii billiondollars, the Department of Agriculture (USDA) has not obtaineda comprehensive evaluation of the school lunch program. The program's goals notwithstanding, over a billion dollars of publicfunds are spent each year without any objective evidence thatthe program is, in fact, safeguarding schoolchildren's health.These considerations, coupled with the possibility that thellIn commenting on our report the Department of Health, Educa- tion, and Welfare (HEW) stated:"The report criticizes the regular Type A schoollunch because it contributes to obesity in somechildren and has not been able to improve ironnutriture. Since the report elsewhere concludedthat present studies of NSLP are inadequate toevaluate nutritional impact, it is premature toimplicate the program on these grounds. This isparticularly true since, as the re0i:t,.p(l.ints outelsewhere, the school lunch provi es only one-sixthof the meals of the participants and can, therefore,only be a supplement to home meals.".", ,We wish to give special emphasis to the fact that our'f port .-'. " ''' :' ,.states a need for further evaluation of NSLP's health i l1lpact.I t does not provide scientific evidence that NSLP as a wholefails to improve iron nutriture, or that it promotes obesity.On the other hand, it does bring (cont. on following page)6

program may have adverse side effects (promoting obesity),indicate a need for further p'r gram evaluations. Some considerations which we believe are important in evaluatingNSLP's health" impact are:--The evaluation pro'cess, in addition to determiningtheprog'r,am's impa'ct on nutr itional status, shouldalso monitor the program's influence on selectedhealth conditions (e.g., the designers of an NSLPevaluation should consider the feasibility of detectirig the program's influence on features Suchas tneincidence and duration of illness, hypertension, tooth decay, etc.).--The evaluation proceSs should selectively focuson those diet variables which are considered tobe the most strategic to NSLP goals, either inthe sense that they have the greatest impact onindividual health or that they, better than anyothers, show whether NSLP is safeguarding theoverall level of schoolchild health as expected(e.g., capable of detecting positive and negative health impacts).--Although the evaluation process may be constrainedto a comparatively small s'arilple of children, thereis an implicit requirement for evaluation resultsto be expressed in terms of their impact on theoverall NSLP population. A sample designed to showthe program'S impact on specific health/nutritionproblems may provide the best means of renderingsuch estimates.(cont. from preceding page) tOgether evidence that: (1)obesity and iron deficiencies constitute a nutritional problem among schoolchildren, (2) the NSLP lunch increases foodconsumption without distinguishing between the needs of underfed and overweight children, and (3) where studied, the NSLPlunch has been found to provide less than one-third of ascl:oolchild's RDA for iron. Most of the stUdies which haveat,tempted to evaluate NSLP'S health impact focused on itsability to improve iron nutriture. Aside from being inconclusive, riot orie of the studies showed any indication ofimproving iron nutriture. On the other hand, such studieshave found indications of an increased prevalence of Obesityamong NSLP participants. These findings, while not necessarily representative of NSLP as a whole, are a cause for concern, and justify further evaluations of the program's healthimpact.7

RecommendationAS a means of resolving existing uncertainties and improving program effectiveness, the Secretary of Agriculture shouldrequire a formal, systematic evaluationof NSLP's performance in meeting legislativeobjectives. The evaluation should be coordinated to utilize the expertise and resources of HEW in all matters pertainingto the health and nutritional status ofschoolchildren; and to provide effectiveand timely reporting of information neededfor congressional oversight.AGENCY COMMENTS AND OUR EVALUATIONHEW advised us by letter dated April 14, 1977, that itwas willing to assist USDA in carrying out the intent of ourrecommendation.USDA in a letter dated April 20, 1977, told us that itrecognized the need for a comprehensive evaluation of NSLP'seffectiveness in meeting legislative objectives. USDA statedthat an evaluation plan projecting FNS's research plans overthe next 5 years has been drafted and is currently under review. It said that the plan calls for developing a methodology for assessing NSLP's nutritio

--Oneslice of whole grain or enriched bread, or an acceptable equivalent. 21 liThe definition of milk waS expanded in 1973 to include fluid - forms of whole, low-fat, skim, cultured buttermilk and fla vored forms of these milks. 2/In 1974, the definition of bread was expanded to include - crackers, taco shells, pizza crust, etc. 3

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