FCMAT
Lassen Union High School District Report
food services department review
Read the report at Lassen Union High School District ↗
Lassen Union High School District
Food Services Review
November 30, 2012
Joel D. Montero
Chief Executive Officer
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November 30, 2012
Roy J. Casey, Interim Superintendent
Lassen Union High School District
55 South Weatherlow Street
Susanville, CA 96130
Dear Interim Superintendent Casey:
In August 2012 the Fiscal Crisis and Management Assistance Team (FCMAT) entered into an
agreement with the Lassen Union High School District for a review of the food service program.
Specifically, the study agreement provided that FCMAT would perform the following:
1. Conduct a review of the Lassen Union High School District’s current child nutri-
tion program including food preparation, ordering, inventory, cash management,
staffing, policies and procedures, federal and state compliance, menu planning,
warehousing and food storage, purchasing and facilities. The team will provide
recommendations for enhancing revenues or implementing changes to reduce the
potential level of unrestricted general fund contribution needed to support the
program and provide a more efficient operation.
2. The district is also requesting a one day review of the Johnstonville School District
food services program, which is under the Lassen Union High School District
administrative oversight for the food service and nutritional program. This compo-
nent will consist of reviewing the food service program operations and make
recommendations to improve the operational efficiency, if any.
This report contains the study team’s findings and recommendations. On behalf of FCMAT, we
appreciate the opportunity to serve you and extend our thanks to all the staff of the Lassen Union
High School District for their cooperation and assistance during fieldwork.
Sincerely,
Joel D. Montero
Chief ExecutiveOfficer
FCMAT
Joel D. Montero, Chief Executive Officer
. .
1300 17th Street - CITY CENTRE, Bakersfield, CA 93
.
301-4533 Telephone 661-6
.
36-4611 Fax 661-63
.
6-4647
422 Petaluma Blvd North, Suite. C, Petaluma, CA 94952 Telephone: 707-775-2850 Fax: 707-775-2854 www.fcmat.org
Administrative Agent: Christine L. Frazier - Office of Kern County Superintendent of Schools
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TABLE OF CONTENTS
Table of contents
About FCMAT .........................................................................................iii
Introduction ............................................................................................1
Executive Summary ..............................................................................3
Findings and Recommendations .....................................................5
Lassen Union High School District ...........................................................5
Johnstonville School District ....................................................................13
Appendices ............................................................................................21
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TABLE OF CONTENTS
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ABOUT FCMAT
About FCMAT
FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify,
prevent, and resolve financial and data management challenges. FCMAT provides fiscal and
data management assistance, professional development training, product development and other
related school business and data services. FCMAT’s fiscal and management assistance services
are used not just to help avert fiscal crisis, but to promote sound financial practices and efficient
operations. FCMAT’s data management services are used to help local educational agencies
(LEAs) meet state reporting responsibilities, improve data quality, and share information.
FCMAT may be requested to provide fiscal crisis or management assistance by a school district,
charter school, community college, county office of education, the state Superintendent of Public
Instruction, or the Legislature.
When a request or assignment is received, FCMAT assembles a study team that works closely
with the local education agency to define the scope of work, conduct on-site fieldwork and
provide a written report with findings and recommendations to help resolve issues, overcome
challenges and plan for the future.
Studies by Fiscal Year
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50
40
30
20
10
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92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12
Lassen Union HigH scHooL District
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FCMAT also develops and provides numerous publications, software tools, workshops and
professional development opportunities to help local educational agencies operate more effec-
tively and fulfill their fiscal oversight and data management responsibilities. The California
School Information Services (CSIS) arm of FCMAT assists the California Department of
Education with the implementation of the California Longitudinal Pupil Achievement Data
System (CALPADS) and also maintains DataGate, the FCMAT/CSIS software LEAs use for
CSIS services. FCMAT was created by Assembly Bill 1200 in 1992 to assist LEAs to meet and
sustain their financial obligations. Assembly Bill 107 in 1997 charged FCMAT with responsi-
bility for CSIS and its statewide data management work. Assembly Bill 1115 in 1999 codified
CSIS’ mission.
AB 1200 is also a statewide plan for county office of education and school districts to work
together locally to improve fiscal procedures and accountability standards. Assembly Bill 2756
(2004) provides specific responsibilities to FCMAT with regard to districts that have received
emergency state loans.
In January 2006, SB 430 (charter schools) and AB 1366 (community colleges) became law and
expanded FCMAT’s services to those types of LEAs.
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ABOUT FCMAT
Since 1992, FCMAT has been engaged to perform nearly 850 reviews for LEAs, including school
districts, county offices of education, charter schools and community colleges. The Kern County
Superintendent of Schools is the administrative agent for FCMAT. The team is led by Joel D.
Montero, Chief Executive Officer, with funding derived through appropriations in the state
budget and a modest fee schedule for charges to requesting agencies.
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INTRODUCTION
Introduction
Background
Located near the city of Susanville in Northern California, the Lassen Union High School
District serves almost 1,000 students at Lassen High School, Diamond Mountain Charter High
School, Credence High School (alternative), and Lassen Community Day School.
The Johnstonville Elementary School District is a single-school K-8 entity that serves approxi-
mately 230 students and is also located near Susanville. While it is a separate district with
separate site administration, it shares a superintendent with the Lassen Union High School
District. Johnstonville Elementary also has seven additional students in the preschool, infant/
toddler program and Steps to Success class. Approximately 40 percent of the students attend
Johnstonville as interdistrict transfer students.
In August 2012, the district entered into an agreement with the Fiscal Crisis and Management
Assistance Team (FCMAT) for a study that would perform the following:
1. Conduct a review of the Lassen Union High School District’s current child
nutrition program including food preparation, ordering, inventory, cash
management, staffing, policies and procedures, federal and state compliance,
menu planning, warehousing and food storage, purchasing and facilities. The
team will provide recommendations for enhancing revenues or implementing
changes to reduce the potential level of unrestricted general fund contribution
needed to support the program and provide a more efficient operation.
2. The district is also requesting a one day review of the Johnstonville School
District food services program, which is under the Lassen Union High School
District administrative oversight for the food service and nutritional program.
This component will consist of reviewing the food service program operations
and make recommendations to improve the operational efficiency, if any.
Study Team
The study team was composed of the following members:
William P. Gillaspie, Ed.D. Judith E. Stephens
FCMAT Deputy Administrative Officer FCMAT Consultant
Sacramento, CA Nipomo, CA
Leonel Martínez
FCMAT Technical Writer
Bakersfield, CA
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INTRODUCTION
Study Guidelines
FCMAT conducted an initial review of the Lassen Union High School District’s nutrition
program in October 2010. A follow-up review was performed in September 2011 to assess
progress in the goals and recommendations of the original study. FCMAT conducted the current
review on October 9-11, 2012 to determine additional progress. The primary objectives were as
follows:
• Review the menu system and ascertain the progress towards compliance with new
program regulations (and the previous recommendations from the state program review).
• Review the variety and customer appropriateness of the menu.
• Informally review the budget and staffing and student participation although these were
not listed as priorities of this study. This review was conducted to determine how the
new meal regulations may affect the program.
• Review the Hazards Analysis and Critical Control Points (HACCP) and wellness
policies.
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EXECUTIVE SUMMARY
Executive Summary
The Lassen Union High School District’s food service operation has struggled for some time
because of an open campus, allowing a large number of students to leave the campus at lunch,
and the low number of students who qualify for free and reduced-price meals. Strict new menu
regulations from the government also make it difficult to provide meals that appeal to the student
clientele.
The district’s menus comply with the new regulations as far as can be determined without a
nutritional analysis of calories and saturated fat. As part of the process of menu certification, the
district is required to complete detailed worksheets. The supervisor attended the state certifica-
tion workshop and understands the steps necessary to complete this process. Since there is a
timeline for completing the menu certification, this should be the department’s top priority.
After certification, the district should implement changes to enhance participation. These
include surveying students to determine their preferences and adding a simple and popular)
second entrée daily to appeal to a larger group. Adding choices will increase food costs; however,
revenues could increase if these changes result in additional participation. The district has solic-
ited bids and communicated with vendors to receive lower prices. This effort should be ongoing,
and the district should consider partnering with the Johnstonville School District to solicit bids
for common products.
Any changes to the menus must meet the new regulations because as part of certification process,
the district affirms to the state that it adheres to these requirements. Although the district is not
required to recertify when changes are made, it must maintain the standards.
The food service supervisor has worked diligently to learn the program requirements, attending
classes and implementing changes to ensure compliance. Current menus are made partially from
scratch as requested by the administration. The snack program was eliminated in hopes of serving
more meals, but this has resulted in decreased income and meal equivalents.
An assessment of meals per labor hour (MLPH) suggests it will be difficult for the program to
become self-sustaining. The productivity number of 14 meals per labor hour this year is almost
half what it was two years ago. If this number remains stable or continues to decline, the district
cannot justify its current staffing levels without accepting that the annual general fund contribu-
tion to the program could be permanent. The food services program had a deficit of $45,000 in
2011-12 and projects a deficit of $31,810 in the current year.
The department has made efforts to improve the nutritional quality of meals and meet program
requirements, but these changes have not resulted in financial solvency. As participation
continues to decrease, the resultant low revenue and current staffing will continue to create a
deficit. Increased reimbursement resulting from menu certification will not significantly affect
this. With the average number of lunches at 72 per day, the six cents of additional income per
meal will translate to less than $1,000 in revenue this year, and the new requirements may actu-
ally increase costs.
The district should make a philosophical as well as financial decision regarding food services.
In recent years, decisions were made to provide more scratch cooking and discontinue a la
carte sales, keep the program self-operational instead of allowing another district to operate it,
and provide the food services staff with sufficient work hours to attract quality personnel. All
these factors affect the department’s financial status. Participation could improve by adding
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EXECUTIVE SUMMARY
menu choices and selling some popular items a la carte, but a contribution from the district’s
unrestricted general fund would likely still be necessary. Therefore, the district should decide the
level of contribution it can afford and the modifications it is willing to make to generate more
revenue.
The district’s wellness and Hazards Analysis and Critical Control Points (HACCP) policies
should be completed to comply with regulations. Since these have been in place for several years,
and the district has received several recommendations to implement them, this should be a high
priority for this school year.
The Johnstonville Elementary School is a separate site but shares the same superintendent as the
high school district and has an effective menu program. The menus meet the requirements and
are generally appealing to students. The cook understands the meal program and has worked
diligently to recreate menus that meet these requirements.
The cook coordinates a reasonably efficient operation; however; the entire program could benefit
from increased efficiencies. Steps that can save time include substituting ready-made bread items
for the home-baked variety and switching from plastic washable trays to disposable ones at lunch.
Students should also be provided with more flexibility in offer vs. serve food selection, saving
time and money.
Lunch participation is high but could be increased with a few simple changes such as providing
additional entrees and gauging students’ opinions on the menus and foods they prefer. Breakfast
participation is low, and the district should consider implementing the recommendations in this
report to increase participation. This should be a high priority.
Overall food costs are low, and the cook is conscientious about utilizing commodities; however,
individual food items may be overpriced. The district should request quotes, investigate the
possibility of combining bidding with Lassen High School and consider joining a food buying
cooperative. With the state of the budget, every avenue of revenue enhancement and cost savings
needs to be considered.
Labor costs are extremely high and include the cook as well as percentages for maintenance,
custodial and secretarial services.
Even if it implemented the changes recommended in this report, the district would likely still
need to subsidize or contribute from the district’s unrestricted general fund to support the
cafeteria fund. The only other alternative would be to contract the program to another district,
but this would entail significant changes that should not be implemented without extensive
consideration of the advantages and disadvantages.
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LASSEN UNION HIGH SCHOOL DISTRICT
Findings and Recommendations
Lassen Union High School District
Menu Program
The Lassen Union High School District’s food services program has experienced additional
obstacles since FCMAT’s last review. As a result of the Hunger-Free Kids Act of 2010, new regu-
lations in the school lunch and breakfast program are being phased in beginning with the 2012-
2013 school year. These are the most comprehensive changes in the program in more than 15
years. The new lunch meal pattern is effective as of July 1, 2012, and the changes to the breakfast
program (except the new milk requirement) will be phased in beginning July 1, 2013.
Districts are required to comply before the end of the school year 2012-2013. Districts will
receive an additional six cents per meal after they have completed a very specific certification
process, which involves submitting menus and a nutritional analysis to the state for approval.
This submittal includes completing a detailed worksheet outlining specifics of the menu offer-
ings. To properly complete this worksheet, the district will need accurate production records,
standardized menus, and nutritional specifications for all food served.
The state approval process is estimated to take 60 days after districts submit materials. Once the
menus are approved, the extra reimbursement will be paid, retroactive to the month of the menus
that were certified. Districts not complying will not receive funds and will be first in line for
administrative reviews in 2013-2014. They will still be expected to comply at that time.
Although these new regulations are intended to improve the quality of student meals, they are
difficult to implement. They include changes in the quantities and types of fruits and vegetables;
limits are established for minimum and maximum levels of calories, meats and breads in the
meals. A summary of these requirements is attached as Appendix A to this report. More detailed
information can be found on the USDA website at the following address:
http://www.fns.usda.gov/cnd/governance/Policy-Memos/2012/SP10-2012ar4.pdf
http://www.gpo.gov/fdsys/pkg/FR-2012-01-26/pdf/2012-1010.pdf
Since last year, the district met many goals regarding staff training and the menu program.
The supervisor took many classes to improve her understanding and skills in child nutrition,
including workshops on the new meal requirements. The supervisor has a thorough under-
standing of the new menu patterns and has been planning menus to comply. Menus have been
simplified to include only one entrée a day in an effort to reduce food costs and streamline food
production.
Production records are in a clear format and are completed daily. These records indicate that
meals served comply with menu regulations, at least regarding the required portions of the
various components; meats, breads, fruits, vegetables and milk. Since the department has not yet
implemented its nutritional analysis program, it is unknown whether these meals meet calorie
and fat requirements until the nutritional analysis worksheets required for the certification are
completed. All indications are that the district will pass certification.
Although progress has been made with standardized recipes and nutrition specifications on prod-
ucts, this project is not yet complete.
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The food supervisor has been conscientious about collecting product specifications, but many of
these records are labels from food boxes, which are difficult to organize. Most nutritional speci-
fications are available online from manufacturers or the USDA. These should be obtained and
maintained in a notebook or file for easy access.
A standardized recipe is one that has been carefully adapted and tested to ensure product consis-
tency, predictable yield and accurate nutrient content. These can also control costs because less
food is wasted. These recipes, which are required as part of meal regulations, have been started
for some food items, but need to be completed for all menus.
Last year, the district purchased nutritional analysis software that will ease the process of developing
recipes, maintaining production records, and performing a nutritional analysis of menus; however,
the program has not been implemented because of time constraints. The FCMAT study team
reviewed the program procedure for creating recipes to complete recipes for one week of the menu.
This type of process will need to be completed for all menus, and once accomplished, a nutritional
analysis of menus can be performed. Production records are also linked to the menus in the
program and can be printed directly, eliminating the need to create them by hand. After the state
meal certification is completed, implementing this program should be a priority for this year
In prior years, the menu consisted primarily of frozen heat-and- serve, fast-food type entrees,
and the district expressed the desire for more homemade-type meals. As a result, the supervisor
has made concerted efforts to offer more entrees that are cooked from scratch. Since pizza is a
favorite of virtually all students, a high-quality frozen pizza is still offered weekly. Although this
product is popular, the district could serve a vended pizza such as the Round Table brand used
by the Johnstonville School District. The district pays $1.25 per slice, which is only 13 cents
more than the frozen pizza. If these two districts bid together, they may be able to negotiate
lower pricing. Most students are brand-conscious, and the name recognition could considerably
increase participation. Vendors can also create products that fit the a la carte regulations, which
would allow a la carte sales.
Most of the remaining choices are home-cooked items. Prior menus also used corn and tortilla
chips as the main grain/bread options. New menus offer whole grain breads, whole wheat pasta
and brown rice for the majority of the grain servings in keeping with the new requirements.
The most difficult aspect of the new menu regulations are the mandated portion sizes. In the
past, menu requirements mostly focused on the minimum servings of food categories (breads,
meats,) and number of calories. The new regulations also mandate the maximum servings of
breads and meats that are allowed to be served in a week as well as maximum average daily calo-
ries. These regulations make menu planning challenging, and current portions appear inadequate
at the high school level.
Additionally, the new regulations include strict requirements for vegetables. Previously, schools
were required to serve a half-cup fruit or vegetable serving at lunch, but the new guidelines
require one cup each of fruits and vegetables to be offered daily (five cups each/week). More
specifically, several vegetable subgroups (dark green, red, and orange, legumes, starchy and a
group called “other” which includes all vegetables not in specific categories) must be represented
weekly in designated serving sizes. The district’s new menus meet these requirements.
The district will need to slightly modify its menu by specifying the type of fresh fruit offered each
day since the menu indicates only ‘fresh fruit’ at present. For planning on a master menu, “fresh
fruit” can be used generically, but the type of fresh fruit must be listed on menus each month
when seasonal availability is known.
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LASSEN UNION HIGH SCHOOL DISTRICT
Another change regarding produce is that students are required to select at least a half-cup
of fruit or vegetable for the meal to qualify for reimbursement. Under the old requirements,
students had the choice of whether to accept these. Unlike the bread and meat components, there
are no maximum-portion restrictions for fruits and vegetables. These criteria promote healthy
choices, but they are not necessarily as appealing to students, and most will not want to consume
large quantities of produce while being restricted on entrée sizes.
Because of the significant menu changes that are mandated and chosen by the district (home-
made vs. “fast-food” options and only one daily entrée choice), the students could be surveyed to
determine their food preferences and which can be provided while remaining within the regula-
tions and budget restraints.
Recommendations
The district should:
1. Obtain food-product specifications online from the manufacturers of the
USDA and maintain them in a notebook or file for easy access whenever
possible. The current method of collecting labels from food boxes is cumber-
some, inefficient and difficult to organize.
2. Use its recently purchased nutritional analysis software to complete standard-
ized recipes, which are required as part of meal regulations, for all menus.
Once this is accomplished, the district should perform a nutritional analysis
of all menus.
3. Investigate the possibility of serving a vended pizza such as the Round Table
brand used by the Johnstonville School District to help increase participation.
4. Evaluate the portions at the high school to determine whether they are
adequate according to the new menu regulations.
5. Slightly modify its menu by specifying the type of fresh fruit offered each day.
6. Survey students to determine their food preferences and which can be
provided while remaining within the regulations and budget restraints.
Budget
The cafeteria budget has required contributions from the unrestricted general fund for the past
few years. The subsidy was $10,000 in 2010-2011, $35,000 in 2011-2012 and is projected to
be $25,000 in the current fiscal year. Revenue has decreased by more than $55,000 since 2010-
2011. Even though staff hours have slightly decreased, labor and benefit costs have increased by
$4,000 since 2010-2011; however, the district predicts that it may not use the $10,000 budgeted
for substitutes this year, so labor may not be as high as originally forecast.
Food costs have decreased by $20,000 since 2010-2011. Ideally, food and labor costs should each be
40% to 45% of revenue, but the district’s labor costs were 54% of revenue and food was 51% this
year. Food has remained at about the same percentage of revenue for the three years of the comparison.
Labor cost percentages appear to have risen more (the difference between 37% and 51%) but
that percentage may be skewed because of the resignation of the entire food service staff before
the end of the contracted year in 2011.
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The changes in the increased deficit and higher contributions are largely because of the elimination
of the snack program and the fact that the number of meals served has decreased slightly (7%). This
had a huge impact on revenue. By removing the snack program, the district hoped to have higher
participation in the meal program, but that did not occur. The other goal was to improve the nutri-
tional quality of the meals, and while this has occurred, fewer students are eating them.
These trends in the cafeteria budget present a problem. If participation continues to be low and
staffing remains the same, the deficit will not improve.
Three-Year Cafeteria Budget Comparison
Percent 2012-13 Percent
2010-11 Revenue 2011-12 % Revenue (Projected) Revenue
Actual Cafeteria Revenue $151,195 $95,903 $93,200
General Fund Contribution $10,000 7% $34,898 36% $25,000 27%
Total Revenue $161,195 $130,801 $118,200
Labor $42,528 $44,323 $43,750
Benefits $16,754 $21,996 $19,560
Total Labor/Benefits $59,282 37% $66,319 51% $63,310 54%
Food and Supplies $80,863 50% $61,444 47% $60,000 51%
Other Expenses $8,761 $13,363 $1,700
Total Expenses $148,906 $141,126 $125,010
Excess or Deficit $12,289 $(10,325) $(6,810)
Excess or Deficit Excluding
Contributions $2,289 $(45,223) $(31,810)
Recommendation
The district should:
1. Determine whether low participation and current staffing levels are acceptable
in the cafeteria budget.
MPLH Comparisons
In 2010-2011, the number of staff hours for three part-time employees was 13.33 per day. An
average of 78 breakfasts and 97 lunches were served daily (175 total meals). A large quantity of
a la carte snacks and entrees were sold, adding another 357 meal equivalents to the total meals
served each day, and meals per labor hour (MPLH) were 27.
In 2011-2012, the staff had changed because of the previous year’s staff resigning. Two new staff
members were hired, and total hours decreased to 11.5 per day. An average of 124 breakfasts and
82 lunches were served per day (206 total) and another 26 meals for the charter school. Average
meals totaled 232 per day for a MPLH of 21. The biggest change in the cafeteria meals that year
was the elimination of the snack bar and a la carte sales except for juice, milk, and individual
entrees sold in meal lines.
In September 2012, the number of meals has decreased to 67 breakfasts and 72 lunches and
another 23 meals at the charter school for a total of 162 daily meals. With 11.5 labor hours, the
MLPH have decreased to 14.
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LASSEN UNION HIGH SCHOOL DISTRICT
The number of total meals served per day has significantly decreased since last year with the
biggest change in breakfasts, which are down 57 per day. The breakfast menus have not changed
since the new requirements for breakfast do not become effective until next school year. Lunches
are down by 10 per day, and free and reduced eligibility is at 23% compared to last year’s 27%.
The participation of eligible students is similar to previous years at 28%. The most significant
change in last year’s practices was the elimination of the snack program; however, the department
still sells a significant number of a la carte entrees in the meal lines, and these are often purchased
as second portions in addition to meals. This year all, a la carte sales have halted except for milk
and juice. Since lunch participation is similar to last year, it is difficult to determine whether the
new menus are having an impact.
As stated in previous reports, much of the low participation is a result of the culture of high
school students (who often do not want to eat in the cafeteria), the open campus policy, and easy
access to fast foods that appeal to students and are often less expensive or offer more food for
the same cost as a school meal. Schools are at a disadvantage because of the restrictions limiting
the menu items (and portion sizes) the students prefer. In addition to the types of food available
off campus, leaving school at lunchtime appeals to many students because of the opportunity to
socialize with friends.
Recommendation
The district should:
1. Decide whether to make changes that may counteract the decreasing number
of meals per labor hour or continue as a self-operating, home-cooking
cafeteria with only one entrée choice and no a la carte sales.
A La Carte Food Sales
Before 2011-2012, the department averaged $433 per day in a la carte sales from a snack bar
window. These sales were factored into the MPLH calculations, which is the reason for the
decrease in successive years. The snack bar was popular, but was discontinued because of the high
labor needs and a lack of proper inventory management.
Only milk, juice, and a few entrees in meal lines have continued as a la carte sales. The problems
with selling entrees a la carte include the fact that many do not fit the more stringent nutritional
requirements for foods sold outside the meal program. A la carte entrees at the high school level
are required to have 400 calories or less and be less than 36% fat. The menu items in the meal
program sometimes exceed those limits, but nutritional requirements for meals are based on the
entire meal, not just the entrée.
Some entrees may meet the requirements, but it would be confusing to students and the staff
if entrees could be sold on some days and not others; therefore, it would be more logical to sell
only full meals (and milk, juice) in the lines. The district plans to use this option. Another option
would be selecting one or two popular entrees that meet the a la carte requirements such as
another kind of pizza or burrito and offer those as daily alternatives with the meal and a la carte.
Pizza is one of the most popular meal items on the menu and students often want extra slices.
However, the pizza served does not meet the fat requirements for a la carte sales.
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LASSEN UNION HIGH SCHOOL DISTRICT
These a la carte rules also apply to any organization on campus. It has been common for clubs to
request pizzas from the kitchen for meetings and sell it to students. While the kitchen receives the
revenue, the product does not meet the nutritional requirements to be sold in this manner. Either
the students should buy a full meal at the cafeteria using their student identification cards, or
the clubs should seek other alternatives. No outside vendor can sell to the club and deliver pizza
or other foods on campus, but students could pick up their own lunches off campus or bring a
lunch from home. As long as food is sold to students on campus, it must fit regulations. If it is
given away, requirements don’t apply.
Lassen High School has experienced ongoing problems with student food sales either not
meeting regulations or competing with cafeteria sales.
The purpose of the competitive foods laws is to prevent food sales outside the cafeteria from
interfering with student participation in the school meal program and, therefore affect the
solvency of the cafeteria fund. The district prohibits student food sales as fundraisers.
The cafeteria plans to eliminate all a la carte sales, but the meal program does not seem to attract
enough students to make the program solvent. A la carte sales previously generated enough revenue to
reduce the deficit. The cafeteria could return some entrees and snacks that fit the nutritional require-
ments and are simple enough for the cafeteria staff to manage. Another option would be to partner
with student groups, using students to help sell foods in the cafeteria snack bar and to share the profits.
This may keep more students on campus and may even draw more students to the meal program.
Recommendations
The district should:
1. Sell only full meals (and milk, juice) in the cafeteria lines. Another option is
to select one or two popular entrees that meet the a la carte requirements to
offer as daily alternatives with the meal and a la carte.
2. Discontinue the practice of allowing clubs to obtain pizza from the kitchen
for meetings and sell it to students. The product does not meet the nutri-
tional requirements to be sold in this manner.
3. Revisit the decision to totally eliminate a la carte sales and return some
entrees and snacks that fit the nutritional requirements and are simple
enough for the cafeteria staff to manage. Another tact would be to partner
with student groups, possibly using students to help sell foods in the cafeteria
snack bar and to share the profits.
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LASSEN UNION HIGH SCHOOL DISTRICT
District Wellness Policy
Wellness policies have been required of school districts participating in the National School
Lunch Program since 2006. This regulation was part of the Child Nutrition Reauthorization
Act of 2004. The Lassen High School District has a policy that covers the basic requirements of
that legislation, including goals for nutrition education, physical activity, and nutrition guide-
lines for all foods available on campus. The policy is generic, and the wellness committee has
not included all the required participants (e.g., food service staff) or been active in promoting
the policy or measuring implementation. During the state nutrition program review (CRE) in
November 2010, the district was cited for lack of policy implementation and measurement, not
having food service represented, and not keeping up to date with newer policy requirements.
The Hunger-Free Kids Act of 2010 specified new requirements for wellness policies, including
the following:
• Designate one or more school officials to ensure that the school complies with the policy.
• Include goals for nutrition promotion.
• Expand the committee members to include physical education teachers and school health
professionals.
• Inform and update the public about the content and implementation of the policy,
The district lacks an active wellness committee and has not followed through with promotion or
implementation of the policy. It does not have a designated wellness coordinator and has not yet
updated its policies to comply with the 2010 requirements. The new requirements were discussed
with district office staff and they plan to begin making the necessary changes. Because schools
face many challenges, it is difficult to have the time and resources to complete all aspects of this
policy. The government recognizes this and provides many guidelines to help districts understand
and implement this important, but time-consuming regulation.
An overview of the wellness policy requirements including a comparison chart of the original
2004 and 2010 regulations and several policy resource links is attached as Appendix A to this
report.
HACCP
A major concern noted in the 2010 CRE was the requirement to create and implement a Hazard
Analysis Critical Control Point (HACCP) plan for the department. This is a comprehensive food
safety plan that has a detailed and specific format and complex methods for ensuring food safety,
and FCMAT also pointed out this issue in a 2011 letter. The district has copied sample policies
from a food safety workshop that the food service supervisor attended; however, it needs to create
policies based on regulations and that apply to its particular operation. Templates are available for
personalizing the district plan on the following USDA website:
http://www.fns.usda.gov/fns/food_safety.htm.
The district is aware of the HACCP requirements and plans to complete these policies. The food
service supervisor is certified in food safety and follows appropriate food safety procedures, but
the department is also required to comply with written policies.
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Recommendations
The district should:
1. Ensure it has an active wellness committee that includes all the required
participants such as members of the food services staff.
2. Ensure the wellness committee is active in promoting the policy or measuring
implementation.
3. Designate a wellness coordinator and update its policies to comply with 2012
requirements.
4. Create and implement a Hazard Analysis Critical Control Point (HACCP)
plan for the department. Policies should be based on regulations and that
apply to its particular operation.
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JOHNSTONVILLE SCHOOL DISTRICT
Johnstonville School District
The scope and objectives of this section of the study were to review the following areas: The
budget and encroachment, including food prices, bidding and labor costs; staff hours including
a review of meals per labor hour and time management; review of menus including status of
compliance with new regulations, appropriateness for student population and staffing levels. Also
reviewed were the wellness policy and HAACP food safety plans and the state CRE review.
Background
The Johnstonville School District participates in the National School Meal Program, providing
students with breakfast and lunch. At the end of September 2012, 49 percent of the student
body was eligible for free and reduced-price meals.
The cafeteria budget requires a contribution from the general fund, and this year’s projections
indicate a subsidy of $33,868 will be necessary, which is 30% of the department’s budget. In the
2011-2012 school year, the unaudited actuals report shows a $30,000 contribution, which was
25% of total revenues.
Labor and benefit costs for the current year are projected at 63% of revenue and food and
supplies at 31%. In the prior year, salaries and benefits totaled 56% and food was 32%. Ideals for
food and labor costs are between 40-45% each.
The kitchen has only one employee, a seven-hour lead cook who is also responsible for menu
planning (including compliance to regulations) and ordering. The average number of meals
served per day is 41 breakfasts and 141 lunches based on the September 2012 reimbursement
claim report. The MPLH is calculated to be 24 to 26 (breakfasts and lunches combined)
depending on the formula used. Target numbers for highly productive programs are in the
30 MPLH range, and a more thorough discussion of this topic will follow later in this report,
including staff efficiencies and suggestions for streamlining procedures.
Budget
The district cafeteria budget requires contributions from the district general fund. In 2011-2012,
the district contributed $30,000 and this year projects a subsidy of $33,000 or 25 to 30% of the
cafeteria budget.
Labor and benefit costs are by far the biggest percentage of the budget, and this year’s projections
indicate that the district will expend $70,918 in these areas (of $113,418 in total revenue). In
addition to the cook’s salary ($25,918), this fund pays portions of other salaries: 6% ($2,488)
of maintenance, 21% ($4,226) of custodial and 33% ($8,314) of the secretary (who processes
applications and claim forms, track daily meals and collects lunch money). Twenty-one percent
of the salaries are for district staff members other than the cook.
While these are all legitimate charges, they affect the department’s labor budget, necessitating
district contributions. Health and welfare benefits alone cost the department $18,478 per year. In
charging salaries for staff members other than those in food service to the cafeteria fund, it must
make sure it monitors the actual time spent on food -service related work according to personal-
ized activity report (PARS) procedures in the school accounting manual.
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Recommendation
The district should:
1. Monitor the time spent performing work related to food service according to
(PARS) procedures in the school accounting manual in charging salaries for
staff members other than those in food service to the cafeteria fund.
Food Costs and Bidding
Overall food costs range from 31% to 43% of budget in the current and prior year; however, a
review of invoices indicated that some individual prices may be high. The district buys from a
few local distributors and has not requested bids from other vendors or discussed better prices
with local vendors.
Milk is relatively expensive, especially the 1% fat variety at 30 cents per carton and the chocolate
milk at 33 cents per eight-ounce carton. Nonfat white milk is 24 cents per carton. Many districts
obtain prices in the range of 20 cents to 21 cents per carton by bidding, but considering the
remoteness of the district and the need to obtain milk from a supplier other than a dairy, it may
not be possible to get significantly lower prices. Other items that appear to be high in price are
corn dogs at 51 cents each and pancake on stick at 48 cents each (compared to 35 cents at other
districts). Bean burritos are 52 cents apiece, which is a reasonable price. The department uses
bulk breakfast cereals and portions them into bowls, which costs 16 cents to 17 cents per serving
and requires more labor. Other districts purchase individual bowls at 19 cents each. Since cereal
is frequently offered at the district, this option should be considered. Chicken nuggets are 13
cents each or 65 cents for a serving of five, about twice the price some districts are pay.
District invoices include a bulk plain bagel for 16 cents each and a whole wheat wrapped bagel
for 31 cents. The plain nonwrapped bagel is a fair price, but the other seems high; however, this
may be because it is wrapped and whole grain. Yogurt costs the district 73 cents per container
versus 48 cents at other districts.
The district indicated that it does not seek bids but uses a local supplier (Morning Glory) for
most supplies and a local produce company for fruits and vegetables.
The district’s remoteness may prevent it from receiving significantly lower prices, but it should
still make the attempt. Sysco delivers to Lassen High School and therefore may be an alternate
choice for Johnstonville. While the district may have some loyalty to local suppliers, competition
can result in better prices from the preferred vendors.
Recommendations
The district should:
1. Investigate the possibility of purchasing individual cereal bowls instead of
portioning bulk cereals onto bowls. Prices may be similar or slightly higher
but this would save considerable staff time and efficiency.
2. Seek bids for food products instead of relying on only one local supplier. The
district should consider bidding with the Lassen Union High School District
for similar products to maximize savings.
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Meal Program
As a result of the Hunger-Free Kids Act of 2010, new regulations in the school lunch and break-
fast program are being phased in beginning with the 2012-2013 school year. These are the most
comprehensive changes in the program in more than 15 years.
The new lunch meal pattern is effective as of July 1, 2012. The changes to the breakfast program
(except the new milk requirement) are not required to begin until July 1, 2013.
Districts must comply before the end of the 2012-2013 school year. An additional six cents per
meal will be provided to districts after they have completed a very specific certification process,
which involves submitting menus and a nutritional analysis to the state for approval. This
submittal includes a completing a very detailed worksheet outlining specifics of the menu offer-
ings. To properly complete it, the district must have accurate production records, standardized
menus and nutritional specifications for all food served.
The state approval process is estimated to take 60 days after districts submit materials. Once
menus are approved, the extra reimbursement will be paid, retroactive to the month of the menus
that were certified. Districts not complying will not receive funds and will be first in line for
administrative reviews in 2013-2014, at which time they will be expected to comply.
These new regulations are intended to improve the quality of student meals, but they are very
challenging to implement. They include changes in the quantities and types of fruits and
vegetables; limits are set for minimum and maximum levels of calories, meats and breads in the
meals. A summary of these requirements is included in the appendix section of this report. More
detailed information can be found on the USDA website at the following Web addresses:
http://www.fns.usda.gov/cnd/governance/Policy-Memos/2012/SP10-2012ar4.pdf
http://www.gpo.gov/fdsys/pkg/FR-2012-01-26/pdf/2012-1010.pdf
The lead cook is responsible for ensuring the program is complies with regulations. This
employee has attended state workshops regarding the new regulations and certification process.
Menus were modified to meet requirements. The lead cook’s production records, which are
meant to document proper quantities of food served to students, were modified to reflect the
new portion sizes. Changing the menus to the new format was complicated because the district
followed a completely different menu option until it was required to change this year.
Menus appear to meet the new regulations, including the correct meal components (meats,
breads, fruits, vegetables and milk) and portion sizes, calories, and saturated fat. The district has
an advantage in assessing the new menus because it already uses a nutrition analysis program and
can confirm in advance that menus meet requirements, saving a tedious step in the certification
process.
Menus are varied and generally appealing to students although a few items such as the taco soup
and chili are unpopular. These items are offered because they are low in cost and often appealing
in cold weather; however, it may be prudent to serve other items. Pizza sticks (cheese stuffed
bread sticks) are a popular and flavorful entrée with an appealing aroma similar to fresh-baked
bread or pizza. Another option is to pair the chili with a small bag of corn chips (Fritos) instead
of cornbread, a popular offering at many districts that also saves time because no cornbread is
prepared.
The district serves only one entrée choice per day. While this can help decrease costs and reduce
labor, some simple additions may prompt more students to participate, especially on days in
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which relatively unpopular entrees are offered. Items that could easily be added to the menu
include yogurt and graham crackers or peanut butter sandwiches.
Many items are home-cooked rather than prepackaged. The cook has recipes for all items as
required; many are from USDA and others have been formulated and entered into the analysis
program.
District administration questioned the practice of serving Round Table Pizza every Friday
because of the cost of $1.25 per slice; however, participation on greatly increases on those days.
The remaining menu choices are low cost, and many are based on commodity foods. A cheaper
frozen pizza could probably be purchased, but this would likely reduce counts because children
are brand-conscious.
Lassen High School uses a quality frozen pizza at $1.18 a slice that is similar store varieties. The
high school could instead use Round Table with the districts bidding together to determine
whether they can reduce the cost. A vended pizza at the high school could also attract more
clientele.
Many home-baked goods are served, including Italian yeast bread, yeast dinner rolls, cookies,
cakes, cornbread, and muffins. These are popular and produce appealing aromas in the cafeteria.
However, because these items are labor-intensive to prepare in a small one-person operation,
the district should evaluate this practice and consider substituting premade items. Many quality
products that are partially baked or can be heated and served while emulating home-made
aromas and taste. Items that should be considered for this change include cookies, yeast breads
and muffins. Cornbread is simple to prepare from scratch, and ripe bananas can be utilized to
make banana bread. Other possibilities include using fresh dinner rolls, frozen proof-and-bake
rolls, or frozen heat-and-serve soft bread sticks similar those served in Italian restaurants. Since
the food budget is low, the district can afford to use some ready-made product even if they cost
more than homemade.
On the day of FCMAT’s site visit, the cafeteria served toast for breakfast using leftover homemade
bread. The cook sliced loaves of bread, placed it on trays, buttered it, and toasted it in the oven, a
process that took approximately 30 minutes excluding the time spent originally making the yeast
bread. A considerable amount of time could be saved by using a purchased product. The cook indi-
cated that purchased bread becomes too hard, but cooking this type of product for a shorter time
should have acceptable results. Likewise, English muffins or bagels can be substituted.
Sugar cookies were prepared from scratch, which took about two hours. Other work was
performed while cookies were baking, but the time spent mixing, scooping and cleaning the
mixer could be eliminated if drop-and-bake cookie dough were purchased. The products avail-
able are acceptable in quality and would produce an aroma that may attract customers.
Although changes in the breakfast menu are not required until next year, the cook plans to begin
making changes this year. Menus do not reflect requirements for next year, but comply with
this year’s required format. Sweet items include the super bun (essentially a fortified doughnut),
many items served with syrup, Frosted Flakes, Fruit Loops, Honey Nut Cheerios and animal
crackers. Using alternatives (English muffins and bagels) more often and serving protein items
more frequently could improve the nutritional quality (and perception) of the menus. Yogurt is
served a couple of times a week, but the only other significant protein choice is scrambled eggs
with ham, served once a month. Protein suggestions that are simple and inexpensive are string
cheese and hard-boiled eggs, which could be offered daily. Ready-made egg patties are available
and could be served on an English muffin to make a breakfast sandwich.
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Recommendations
The district should:
1. Substitute other items for those that are unpopular to students such as
taco soup and chili. The possibilities include pizza sticks or pairing the
chili with a small bag of corn chips instead of cornbread.
2. Add some simple items to the single entrée choice offered per day to
increase participation. Items that could be added include yogurt and
graham crackers or peanut butter sandwiches.
3. Investigate the possibility of bidding with the Lassen Union High School
District for Round Table pizza in an effort to obtain better pricing.
4. Evaluate the practice of substituting premade items for home-baked
goods such as Italian yeast bread, yeast dinner rolls, cookies, cake, corn-
bread and muffins. These products are less labor-intensive.
5. Improve the nutritional quality of menus by using alternatives to sweet
items more often and serving protein foods more frequently.
Meals per Labor hour and Staff Efficiency
The number of meals per labor hour (MPLH) is the most commonly used method of assessing
staffing needs and productivity in a food service operation. While there is no universally agreed-
upon method for calculating these or consensus as to the ideal numbers, experience indicates
what is effective in highly productive/financially solvent operations.
The Johnstonville School District uses the following formula:
One meal is equal to one lunch, and three breakfasts are equal to two lunches (or .67 of a lunch).
The district lists a factor of .33 for snacks, but does not serve snacks and figures breakfast meals
separately from lunch. The CSEA contract requires MPLH for breakfast to be 18-38 MPLH
and lunch 18-24. The kitchen has only one seven-hour person. The calculation also counts one
hour for the custodian to help serve, but this rarely happens so only the seven hours should
be counted. It is unusual to count MPLH separately for breakfast and lunch, and this does not
accurately reflect the workload since preparation for these meals often overlaps.
The district formula is excessively complicated. Breakfast can be and often is counted as a
fraction of lunch because it requires less preparation. However, because school meals use more
convenience products than in the past (even if they utilize more scratch cooking like the district)
both meals can be counted as equal to simplify the calculation. Therefore, daily breakfasts and
lunches should be added together and given equal weight. The following, using September 2012
meal counts, would be a simpler formula:
Total breakfasts = 704; total = lunches 2,393 = 3,097/17 days = 182 meals per day/7 hours = 26
MPLH (using the district’s formula of .67 breakfast/1 meal - would result in 24 MPLH).
Averaging the district’s contract requirements for breakfast and lunch results in a range of 18 to
31 MPLH. Eighteen is excessively low considering the simplicity of school meals but the higher
range is similar to the 30 MLPH target usually recommended by FCMAT food-service reviews
as a result of experience and observations of successful districts. Twenty-six MPLH is reasonable
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considering the cook’s other responsibilities, but a few changes in the menus and procedures
could ease the workload of this employee and help increase participation and MPLH.
The cook’s responsibilities that go beyond meal service and include planning and analyzing
menus, and ordering food. This position also has become familiar with the new regulations,
revised menus and prepared them for submittal to the state for certification, which will be a
time-consuming process. While occasional extra time may be necessary for duties such as the
new menu certification process, or planning and ordering food for the beginning of school, seven
hours a day should be adequate with a few steps to simplify the process.
Significantly reducing the number of home-baked items would free time in preparation and clean
up. The district also is still uses plastic trays for lunch service, and these must be scraped and
washed. Utilizing disposable trays would add some costs, but could save about an hour a day that
could be used for other planning and ordering duties.
The cook manages her time effectively overall, multitasking on preparation and clean-up, and is
punctual for meal service. The cook’s hourly wages are reasonable at $16.85 per hour. A careful
review of menu items and more streamlined methods should result in completion of the required
tasks without extra time.
Other Program Issues
Coordinated Review Effort (CRE)
A state food service program review was conducted at the Johnstonville School District in May
2012, and the results were positive. A few minor areas were noted as being out of compliance,
but simple corrective actions were completed, and the district passed the review.
The state reviewer had only one modification for the district’s wellness policy regarding moni-
toring and documenting implementation.
The summation report for this review recognized the conscientiousness of the staff and the effec-
tiveness of the meal program.
Meal Counting
The method of recording reimbursable meals at breakfast is out of compliance. Students are
marked off on rosters as they come through the line, but they should be identified by speaking
their names instead of by recognition. Instead, the district serves several students at a time
and attempts to mark them off by visual identification once they are seated at the tables. This
practice is prohibited, and the district could be cited at the next CRE. The new guidelines will
also require breakfasts to be reviewed. The cook indicated she cannot properly record students
without the help of another staff member. Slight modifications in the serving process would
allow for proper recording. A few students at a time could be marked and served as they line up,
and this could be repeated throughout the serving period. The process could also be simplified if
students selected own food rather than having everything served to them.
Offer vs. Serve
The district meal planning option includes the approach known as offer vs. serve. This means
that all the foods on the menu are offered (meats, breads, fruit, vegetables and milk), but
students need to be served or select only some. Four items must be served at breakfast and five
at lunch, but in both cases, students need to take (be served) only three. Site observation and in
discussions with the cook found that this is not the practice. Instead, students are served all items
unless they indicate otherwise.
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The government provides the offer vs. serve option to save money, and students are more likely
to consume foods if they choose what is placed on their trays. When students are served every
item, many foods wind up being discarded. Service would also be faster if the cook served only
items that must be dished and allowed the students to choose the rest. All but the smallest
students should be able to accomplish this task (the serving line is taller than some of the younger
children). The only restriction in what needs to be selected is the number of items listed above
and the fact all students must take a fruit or vegetable beginning this year. Allowing students
to have more flexibility in selection may also make the meal program more appealing to picky
eaters.
Participation & Meal Pricing
The district charges paid students $1.40 for breakfast and $2.50 for lunch. Prices charged to
students that do not qualify for free or reduced-price meals have recently been addressed by the
USDA and state. The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296, requires that
meals for non-needy students are not subsidized by federal reimbursements for meals of needy
students. Guidelines on this issue are posted on the following USDA websites:
http://www.fns.usda.gov/cnd/Governance/Legislation/Pricing_Equity_Facts.pdf
and http://www.fns.usda.gov/cnd/governance/Policy-Memos/2011/SP39-2011osr.pdf
In summary the ruling indicates that a district’s average meal prices should be an amount that is
at least equal to the difference between the higher federal subsidies for free meals and the lower
subsidies for paid meals.
The current federal reimbursement for free lunch is $2.86 and 27 cents for paid lunches, and the
difference is $2.59, which is the minimum the district should charge. It could be rounded up to
$2.75, which should be affordable to families and will add a small increase in revenue. Because
the difference in the free and paid breakfast reimbursement is $1.28, the current breakfast cost
is appropriate. Meal prices should be adjusted each year to reflect yearly increases in reimburse-
ments.
Participation in the program is high. At lunch, the district captures 82% of its free students,
67% of its reduced-price students, and 34% of those who pay full price. Breakfast participation
is lower with 33% of free, 3% of reduced-price students and 5% of paid students. Reduced-price
students pay the allowed 40 cents a meal although some districts waive this charge to encourage
additional participation. The 40-cent share of cost would be lost, but the $1.15 at breakfast and
$2.46 at lunch may be realized for more students.
In the CRE review, the state consultant mentioned the school’s low breakfast and suggested that
the district consider alternative times and options. With a relatively high number of free and
reduced students, capturing more breakfasts would increase revenue. Options could include
offering “grab and go” sack breakfasts that could be eaten in the classroom (with the district’s
support) or a breakfast scheduled at morning recess. Students often want breakfast, but do not
arrive at school in time.
Marketing any positive program changes (such as menu changes discussed previously and any
changes to times or options for breakfast) may also help increase participation. Making diligent
efforts to educate students and families about the importance of breakfast and its correlation with
academic success may make more families consider participating.
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APPENDICES
Appendices
A: Summary of New Nutrition Standards
B: Study Agreement
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APPENDICES
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APPENDICES
NEW NUTRITION STANDARDS
FOR NATIONAL SCHOOL LUNCH & BREAKFAST PROGRAMS
As a result of the Hunger-Free Kids Act of 2010, new regulations in the school lunch and
breakfast program are being phased in beginning with the 2012-2013 school year. These are
the most comprehensive changes in the program in more than 15 years.
The new lunch meal pattern is effective as of July 1, 2012. The changes to the breakfast
program (with the exception of the new milk requirement) will be phased in beginning July 1,
2013.
Districts must comply within the school year 2012-2013. An additional 6 cents per meal will be
given to districts after they have completed a very specific certification process, which involves
submitting menus, production records, recipes and nutritional analysis to the state for approval.
The approval process is estimated to take 60 days after districts submit materials. Districts not
complying will not receive funds and will be first in line for administrative reviews in 2013-2014.
They will still be expected to comply at that time.
The key changes for children in K-12 are as follows:
School Lunch and Breakfast Programs
Only one menu planning approach is allowed – a food based plan based on age/grade
groups
Fruits and vegetables are separated into two separate food components
Requires a daily fruit serving
At lunch specifies daily and weekly minimum serving sizes of fruits and vegetables
Required portion sizes have increased.
At lunch requires weekly minimum servings of vegetable subgroups, including dark
green, red/orange, bean/pea (legume), starchy, and ‘other’ vegetables.
Students must select at least ½ cup fruit or vegetables for the meal to be reimbursable
(previously schools were required to offer these but students were not required to take
them).
Requires daily minimum servings of grains plus weekly minimum and maximum servings
Weekly portions allowed have been decreased.
In school year 2012-2013, 50% of grains served in lunches must be whole grain. In
2014-2015, all grains must be whole grain. Similar requirements apply to breakfast
beginning in 2013-2015.
Only Fat-Free (flavored or unflavored) and 1% low-fat (unflavored) milk are allowed.
Calorie minimum and maximum levels are required (previously it was only minimums).
Weekly minimum and maximum servings of meat/meat alternates as well as daily
minimums. The maximums reduce previous serving sizes allowed in a week.
At breakfast, meat/meat alternates may not be offered until minimum grain requirements
are met.
By the year 2014-2015, 1 cup of fruit must be offered daily at breakfast
Limit on saturated fats but not total fats (as allowed by calorie limits)
Trans fats are limited (this was already required by California law)
Sodium limits will be phased in (declining in amounts beginning in 2014-2015 and
finalizing in 2022-2023).
A 3-year administrative review (previously called CRE) will begin in 2013-12014
(previously reviews were every 5 years)
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APPENDICES
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APPENDICES
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APPENDICES
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APPENDICES
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APPENDICES
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