Detailed Information on the
National School Lunch Assessment

Work to improve certification and non-certification processes to reduce erroneous payments.

Establish regulatory requirements for a school food safety program based on HACCP principles.

Conduct nationally representative study updating information on the nutrient content of meals.

Work to produce a reliable estimate of erroneous payments by 2007.

Measure: Rate of National School Lunch Program participation among U.S. school children

Explanation:

Measure: NSLP elementary and secondary schools offering meals consistent with the Dietary Guidelines for Americans recommendation for total fat.

Explanation:Identifies the proportion of schools that offer meals that, on average over the course of a week, provide 30% or less of their calories from fat.

Measure: NSLP elementary and secondary schools offering meals consistent with the Dietary Guidelines for Americans recommendation for saturated fat.

Explanation:Identifies the proportion of schools that offer meals that, on average over the course of a week, provide less than 10% of their calories from saturated fat.

Measure: NSLP elementary and secondary schools offering meals consistent with the Dietary Guidelines for Americans recommendation for iron.

Explanation:Identifies the proportion of schools that offer meals that, on average over the course of a week, provided one-third of the Recommended Dietary Allowance for iron.

Measure: Dollars lost to error in the NSLP

Explanation:These data represents a national estimate for NSLP erroneous payments developed through the Access, Participation, Eligibility and Certification study (FNS, 2007). 2006 data is based on the 2005-2006 school year. The study methodology derived separate estimates of erroneous payments from each source of error for NSLP; interaction between sources of error can affect the actual erroneous payment that results from any single transaction in NSLP. Therefore, the combined estimates provided below should be considered an upper bound of an overall estimate of payment error for NSLP. Targets represent steady reductions in the rates of both certification-related and non-certification-related erroneous payments in NSLP. USDA is seeking a 2 percent decrease in the certification-related erroneous payment rate, and a 4 percent decrease in the non-certification-related erroneous payment rates. However, dollar figures increase over time as a result of overall program growth. If the program outlays were held constant at the 2006 level, this measure would show a decrease in dollars lost due to program error.

Measure: Rate of National School Lunch Program participation among U.S. school children

Explanation:

Measure: % of NSLP meals out of compliance with food component/meal pattern requirements

Explanation:NSLP regulations require meals to meet specific food-based standards in order to be eligible for reimbursement. The purpose of these requirements is two-fold: to ensure that the meals offer sufficient and adequate food value to justify a Federal payment, and to ensure that meals contain the proper mix of food components to promote healthy diets for participating students. The Department tracks the percentage of NSLP meals out of compliance with food component/meal pattern requirements as a measure of the meals consistency with program rules, and as an annual measure of progress for the long-term measure of improving the meals offered to students (as assessed more formally through the periodic School Nutrition Dietary Assessment study). Data for this measure is aggregated from the Coordinated Review Effort, a Federally-mandated program of State-level reviews of school food service operations.

Measure: Rate of administrative error in NSLP eligibility determination

Explanation:USDA collects annual data on the rate of administrative error in NSLP eligibility determination. Administrative error reductions reduce the rate of erroneous program payments (both overpayments and underpayments).

Measure: Rate of verified applications not supported by adequate income documentation

Explanation:Represents the rate of verified applications determined ineligible in those school food authorities where applications were randomly selected. Data for 2004-2005 excludes 5 States (HI, MA, NC, OH, RI) because data was not submitted to FNS or was invalid.

Is the program purpose clear?

Explanation: Goal - - safeguarding the health and well-being of Nation's children and encouraging the domestic consumption of nutritious agricultural commodities

Evidence: National School Lunch Act, Child Nutrition Act

Does the program address a specific and existing problem, interest, or need?

Explanation: The program provides nutrient dense meals to children, including free or low cost meals to low-income children.

Evidence: National School Lunch Act, School Meal Initiative (SMI) Regulations, Team Nutrition

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: On a daily basis serves nearly 6 out of 10 children enrolled in nearly 100,000 schools. Nearly half of all participants (47%) receive free meals. Meals served to children who do not qualify for free or reduced price meals receive a subsidy of 15-25% of their purchase price.

Evidence: The NSLP is available to nearly all children enrolled in public schools and many in private schools. In 2006 the program will serve an average of over 30 million meals each school day.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The NSLP is the sole mechanism for ensuring near universal access for meals to low income children in public and private schools. The NSLP sets national meal standards consistent with dietary guidelines and ensures that meals meet basic nutritional requirements. Reimbursement rates are intended to match the costs of producing meals.

Evidence: NSLP is available in nearly all public schools. GAO found that reimbursement rates for free meals tie closely to the cost of producing meals. Information on Meal Costs in the National School Lunch Program. RCED-94-32BR December 1, 1993

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The program is designed to provide access to meals, in particular to low income children, with minimum barriers and administrative costs. Recent legislative changes, including mandatory direct certification of children in Food Stamp households, full year eligibility, and increased verification of error prone income applications, target the problem of certification inaccuracy, which has been an issue of concern in recent years. The Agency has also undertaken administrative action, including increased oversight and reporting on the verification process, to reduce and prevent certification problems

Evidence: Child Nutrition and WIC Reauthorization Act of 2004; USDA's 2005 Performance and Accountability Report, pp. 362-363.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: NSLP is one of 15 Federal nutrition assistance programs that are designed to work together to reduce hunger and improve diet quality for children and low-income people in the United States. USDA uses measures of the prevalence of very low food security, and dietary quality as reflected by USDA's Healthy Eating Index, for children and low-income people, to track the overall outcomes to which nutrition assistance programs contribute. NSLP's role in advancing these outcomes is to provide nutritious meals to children at school, including free or low cost meals to low-income children. USDA makes use of two long-term outcome measures to assess the specific contribution of NSLP to the Department's strategic objectives for nutrition assistance: 1) the rate of NSLP participation among U.S. school children, and 2) the nutritional content of NSLP meals. These two measures are clear, easily understood, quantifiable outcomes of NSLP operations - the program's success in reaching its target population, and the extent to which meals offered contribute to and promote healthier diets. The relationship between changes in these program outcomes and population-wide food security status and dietary quality would be impractical to quantify, because of the conceptual difficulty of attributing changes in these complex population-wide metrics to specific influences. However, the program's premise is that the provision of nutritious meals in school, consistent with dietary guidance, will reduce the risk of hunger and promote good diet quality among those served, and thus reduce the overall prevalence of very low food security and improve diet quality among program eligibles over the long-term. USDA also makes use of a number of performance metrics to assess accomplishment of USDA's objective to improve nutrition assistance program management within the NSLP. The planned outcome measure for this objective is the dollars lost to error in the NSLP. Baseline data is currently being analyzed, and is expected to be ready in 2007.

Evidence: USDA Strategic Plan 2005-2010; correspondence with OMB on "Demonstrating Results"; internal USDA planning documents.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: USDA has set quantitative targets reflecting meaningful program results and steady improvement for each of NSLP's long-term performance measures, including a gradual increase in the proportion of U.S. school children participating in the NSLP, and a goal that all meals offered through the NSLP are consistent with the Dietary Guidelines recommendations for total fat, saturated fat, and iron by 2009. Once baseline data for the NSLP improper payments measure is ready, USDA will build ambitious and steady reductions in such errors into its targets for that measure.

Evidence: USDA Strategic Plan 2005-2010; correspondence with OMB on "Demonstrating Results"; internal USDA planning documents. The targeted nutrients included in the long-term measures are a subset of school meals nutrition standards required under program regulation. Total fat and saturated fat were selected because of the relationship between dietary fat and risk for heart disease. Iron was selected because it is the only nutrient among those included in school meals standards for which significant levels of clinical deficiency are found in childhood. The estimated prevalence of iron deficiency among and adolescent females aged 12-19 years is 9%-16% (NHANES 1999-2000). Iron deficiency in childhood and adolescence can adversely affect learning and development.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: USDA makes use of four annual performance metrics that link to its long term measures, consistent with the logic of the program: * USDA tracks the rate of NSLP participation among U.S. school children as a measure of concrete program results linked to the budget request, and the outcome of efforts to ensure access to NSLP meals for all eligibles who wish to participate. * The Department tracks the percentage of NSLP meals out of compliance with food component/meal pattern requirements, a measure of the meals consistency with program requirements, and as an annual measure of progress for the long-term measure of improving the meals offered to students. USDA also makes use of two annual efficiency measures: the rate of administrative error in NSLP eligibility determination, and the percentage of applications reviewed in the verification process with a certification status not supported by adequate income documentation. These latter two metrics represent important parts of the NSLP free and reduced price eligibility certification process. Problems in these areas result in increased risk of NSLP payment errors. These metrics are discrete, quantifiable, and measurable metrics that are at once logically linked to long-term goals, and focused on common-sense outcomes of program operations. The stewardship measures, while process-oriented, are also critical to Federal management responsibilities.

Evidence: Correspondence with OMB on "Demonstrating Results"; internal USDA planning documents.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: USDA has identified clear baselines, and sets specific, ambitious but reasonable targets for each of its annual NSLP performance measures: * Targets for the number of children to be served each school day in NSLP are based on projected needs estimated for the budget process, with the intention of ensuring access to meals for all eligible children who wish to participate. * Though the percentage of NSLP meals out of compliance with food component/meal pattern requirements has been very low for a number of years, USDA targets continued high and improving performance in this area with targets that further decrease this rate. * USDA also targets steady reductions in the rate of NSLP administrative error, and the rate of verified applications not supported by adequate income documentation.

Evidence: Correspondence with OMB on "Demonstrating Results"; internal USDA planning documents.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: USDA regulations and oversight and technical assistance processes are designed to ensure that State agencies, school food authorities (SFAs) and other program partners, manage operations in support of annual and long term program goals, including regular reporting of key performance information. State agencies regularly collect data on the number of schools participating in the NSLP, the total enrollment of these schools, and the number of free and reduced price eligible students; this data is reported annually to USDA. SFAs also report monthly data on program participation by meal eligibility category. SAs report annually to USDA on the results of program reviews under the Coordinated Review Effort, and have recently begun annual reporting on the results of the eligibility verification process, including a report identifying any areas of weakness revealed by the reporting and the corrective action which will be implemented to address the weaknesses. USDA also works closely with the professional association for school food service, the School Nutrition Association, to support and strengthen the commitment of program partners, in particular SFAs, to program goals. Program support at the local level has been increased through programs such as Team Nutrition Schools and the HealthierUS Schools Challenge, which recognizes schools which have improved the quality of foods served and provide students with more nutritious, healthy choices. SNA has adopted USDA's goals for the NSLP into its own standards and recommendations for the school food service community.

Evidence: National School Lunch Act; 7 CFR 210 (NSLP regulations) Child Nutrition Management Evaluation Guidance; CRE Guidance; Team Nutrition/HealthierUS School Challenge materials; ; FNS participation in national/SNA conferences, SNAs Keys to Excellence standards and endorsements of key training/technical assistance documents (Changing the Scene, etc.), Team Nutrition Schools and HealthierUS Challenge programs.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: National studies examining the nutritional quality of NSLP meals are conducted about every five years by independent contractors. CRE reviews are conducted on a regular 5 year cycle; reviews are comprehensive and corrective action is required for deficiencies identified in the reviews. In 2004, USDA completed an evaluation of a range of alternatives to the NSLP certification and verification processes, with an eye to identifying improvements, that also provided important data on the existing processes. Data collection for a national study examining the NSLP eligibility determation process and improper payament rate will occur in School Year 2005-06. This study will be replicated on a 5-year cycle pending appropriate funding approval. Annual collection of results of the eligibility determination and verification process at the Local Education Authority (LEA) level began in School Year 2004-05. In School Year 2004-05, an annual review of a statistical sample of SFA application eligibility determinations to measure changes in adminstrative error rates was initiated. USDA manages an ongoing program of studies targeted at special issues affecting program operations, such as evaluation of the certification alternative pilot studies, assessment of the feasibility of computer matching for eligibility determination and verification, certification accuracy, competitive foods, and assessment of the fruit and vegetable pilot program.

Evidence: 'School Nutrition Dietary Assessment Study (SNDA) I (SY 1991-92), SNDA-II (SY 1998-99) and SNDA III (SY 2004-05); Evaluation of the National School Lunch Program Application/Verification Pilot Projects (2004); NSLP Application, Participation, Eligibility, and Certification (APEC) Study (SY 2005-06);SFA Verification Summary (SY 2004-05). Regional Office Review of Applications(RORA)-2005 (SY 2004-05). Results of FNS-sponsored research are posted at www.fns.usda.gov/oane. Economic Research Service's Effects of Food Assistance and Nutrition Programs on Nutrition and Health (2004)

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Program budget requests routinely estimate the effect of legislation, policy changes, and program participation trends on program costs. Budget requests are tied to the performance goals of the USDA Strategic Plan, as reflected in the Summary of Budget and Performance budget exhibit.

Evidence: FNS FY 2007 budget submission. USDA Strategic Goal 5: Improve the Nation's Nutrition and Health and its related objectives: 5.1-The Reduction and Prevention of Hunger by Improved Access to Federal Nutrition Assistance Programs and Strategic Goal and 5.2-Eating Habits More Consistent with the Dietary Guidelines for Americans.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The Agency is working toward a consistent approach to developing a shared agenda with State Agencies. It is exploring the balance between administrative data collected and burden placed on partners. It is seeking to obtain adequate resources to conduct studies to fill information gaps.

Evidence: A FNS-states working group developed strategies to encourage grantee commitment to performance goals. FNS staff are conducting a top-to-bottom assessment of current administrative data collections to eliminate unnecessary items and determine what changes can be made to support performance measurement

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: USDA collects monthly meal service data from its State partners structured by income eligibility status of recipient, along with information on student enrollment levels in participating schools, data from the eligibility verification process, expenditures of State Administrative Expenses, and a range of additional information used to improve performance. State agencies also report annually on the results of program oversight reviews which are conducted in accordance with uniform standards and procedures established by the Agency (Coordinated Review Effort).

Evidence: CRE Guidance; 7 CFR 218 (CRE regulations); FNS-640 (CRE Data Report); CRE Data Annual Reports

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: State agencies and program operators are reviewed though Management Evaluations (SAs) and the Coordinated Review Effort (School Food Authorities). Identified program deficiencies must be addressed through corrective action and improperly paid program funds are recovered. Future payments may be withheld if deficiencies are not corrected.

Evidence: Child Nutrition Management Evaluation Guidance; 7 CFR 218 (CRE regulations); CRE Guidance

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: Funds are obligated consistent with program regulations that require reimbursement only for meals that meet stringent program standards. Funds are obligated appropriately and consistently for their intended purpose and within a timely manner and schedule.

Evidence: SF-132, Apportionment and Reapportionment Schedule; SF-133, Report on Budget Execution and Budget Resources; and Financial Status Report (SF-269).

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: Sub grantees are required to use approved competitive sourcing in program procurements. The agency works with State agency partners to identify, develop, and provide funding where available for IT improvements to increase program efficiency. We are finalizing a new procurement rule aimed at improving efficiencies SFA procurement practices and State agency oversight of procurement, and will issue comprehensive guidance and conduct training on procurement once the rule is finalized. USDA makes use of two annual efficiency measures: the rate of administrative error in NSLP eligibility determination, and the percentage of applications reviewed in the verification process with a certification status not supported by adequate income documentation. These two metrics represent important parts of the NSLP certification process. Problems in these areas result in increased risk of NSLP payment errors.

Evidence: NSLP Regulations

Does the program collaborate and coordinate effectively with related programs?

Explanation: The National School Lunch, School Breakfast and Child are all designed to provide nutritious meals to children in school and child care settings. A single grantee may administer all three programs. In addition, NSLP coordinates with the Food Stamp Program through the use of "categorical eligibility," whereby children participating in households receiving food stamps may be certified for free school meals without additional application or income documentation requirements. There is also statutory authorization for information exchange with related programs such as TANF, Medicaid, and SCHIP.There is also statutory authorization for information exchange with related programs such as TANF, Medicaid, and SCHIP. Our nutrition education efforts, such as Making it Happen, Changing the Scene, and HealthierUS Schools support the goals of the NSLP

Evidence: The programs use common eligibility guidelines and reimbursement rates. Procedures are harmonized to reduce grantee administrative burden. Within the next 4 years, all States will be required to ensure that all students in food stamp households are directly certified for free meals, improving program participation and eliminating burden for both households and School Food Authorities.

Does the program use strong financial management practices?

Explanation: Financial Mangement practices of the agency comply with 1) Federal financial managment system requirements, 2) Federal accounting standards and 3) the Standard General Ledger at the transaction level. Financial Management practices applicable to the program are established in program regulation and OMB Circulars. Program regulations stipulate that the agency perform state and local evaluations and review claims for meal service & meal counting and claiming practices. Federal financial management reviews assure that administrative costs are accounted for properly.

Evidence: Guidance requirements: National School Lunch Act and program regulations; OMB Circulars: A-87 (Cost Principles for State, Local, and Indian Tribal Governments), A-102 (Grants and Cooperative Agreements with State and Local Governments), A-123 (Management Accountability and Control), A-136 (Financial Reporting Requirements). Reports/procedures/activities: USDA Financial Statement audits; Program management evaluations; Program counting & claiming reviews; Federal Financial managment reviews.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: Certification inaccuracy has been a concern of the agency for a number of years. By law, program eligibility must be determined from the documentation provided by the applicant and is accepted at face value. The agency has conducted pilot programs in over 20 School Food Authorities to test alternative approaches to certification and verification which may reduce certification inaccuracy, and contracted for an extensive evaluation of the results of these pilots. The agency worked with Congress to incorporate provisions in reauthorization legislation to address certification problems, and new requirements such as mandatory direct certification, household applications, and year long eligibility are directed at improving certification accuracy. FNS is revising application design and increasing the number of languages in which translations are available to improve communication of program requirements to participating households. NSLP does not yet have a measurement of improper payments as required by IPIA. A study is in progress which will produce this measurement for school year 2005-2006. The result will be available in 2007. USDA has implemented new statutory provisions to require the use of direct NSLP certification for children in households that receive Food Stamps. In FY 2005, FNS began an annual review of a statistical sample of the administrative accuracy of SFA application eligibility determinations, which showed a low rate of errors. Results of future review cycles will be used to measure changes in administrative error, to assess the impact of corrective action and to target and to focus future corrective activities.

Evidence: Guidance requirements: National School Lunch Act and program regulations; OMB Circulars: A-87 (Cost Principles for State, Local, and Indian Tribal Governments), A-102 (Grants and Cooperative Agreements with State and Local Governments), A-123 (Management Accountability and Control), A-136 (Financial Reporting Requirements). Reports/procedures/activities: USDA Financial Statement audits; Program management evaluations; Program counting & claiming reviews; Federal Financial managment reviews.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Grantee (State agency) activities are assessed annually or biennially through a structured Management Evaluation Process. Sub-grantees (School Food Authorities) are reviewed on a five year rotation using agency established procedures; A summary of the results of the reviews are reported annually to the agency.

Evidence: Child Nutrition Management Evaluation Guidance; 7 CFR 218 (CRE regulations); CRE Guidance

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: USDA collects monthly meal service data from its State partners structured by income eligibility status of recipient, along with information on student enrollment levels in participating schools, expenditures of State Administrative Expenses, and a range of additional information. Grantee data is reported publicly in summary form on the FNS web site, and is provided in detail upon request. The agency collects annual performance data for program reviews conducted by State agencies, but does not publish information at the grantee level or for the public. The agency also collects verification data for all School Food Authorities nationwide to improve the availability of data on certification and verification.

Evidence: 7 CFR 245 proposed rule Determining Eligibility for Free and Reduced Price Meals and Free Milk in Schools -- Verification Reporting and Recordkeeping Requirements

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: There have been steady increases in the rate of NSLP participation among U.S. school children over the last five years. The proportion of schools offering meals to students that are consistent with the Dietary Guidelines for Americans with regard to total fat and saturated fat increased substantially between 1992 and 1999. Cross-Cutting Measures: Reductions in the rate of food insecurity with hunger were somewhat ahead of target through 2000. Rising unemployment and increased poverty have contributed to an increase in the rate of very low food security in subsequent years. There was a small improvement in the HEI between 1996 and 1999-2000.

Evidence: NSLP administrative data; National Center for Education Statistics data on school enrollment; School Nutrition Dietary Assessment Study I & II; USDA Household Food Security reports; Healthy Eating Index report.

Does the program (including program partners) achieve its annual performance goals?

Explanation: NSLP consistently serves meals to school children in 90% of U.S. schools, roughly half to low-income children for free or at reduced price, thus maintaining effective program access for all eligibles who wish to participate. Over 99% of reimbursed meals have been in compliance with food component/meal pattern requirements over the last five years. The rate of administrative certification error in the program declined from 6% to 4% between 2001/02 and 2004/05. The rate of verified applications not supported by adequate income documentation increased between 1987 and 2005; however, this may have resulted largely from changes in the verification sampling methodology, which has focused increasingly on error-prone certifications.

Evidence:

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: Program has achieved substantial improvement in meal quality without changes in program reimbursement rates. Second 5 year cycle of Coordinated Review Effort shows significant improvement in percentage of large SFAs, which account for about 25% of program enrollment, meeting payment accuracy targets( from 79.3% during the first 5 year cycle to 84.5% during the second cycle) The overall percentage meeting payment accuracy targets increased from 85.6 to 85.9% from the first to the second cycle. Nationwide study currently underway will establish a baseline payment error rate and provide information on certification accuracy that can be used to target areas for ongoing improvement in program efficiency and effectiveness.

Evidence: School Nutrition Dietary Assessment Study I & II; analysis of Current Population Survey; Access, Participation, Eligibility, and Certification Study (ongoing).

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The NSLP serves a high proportion of the low income student population (almost 60%) on a daily basis vs. 23% for the School Breakfast Program (SBP); meals served in schools are nutritionally superior to non-school meals; nutritional impacts are significant when measured over a 24 hour period. More than 95 percent of students who were approved for free and reduced price meal benefits on the basis of an application were administratively approved at the correct benefit level, based on the information in the application file.

Evidence: Children's Diets in the Mid-1990s: Dietary Intake and Its Relationship with School Meal Participation - January 2001; NSLP Administrative Data; Regional Office Review of Applications(RORA) 2005; Effects of Food Assistance and Nutrition Programs on Nutrition and Health - Volume 4, Executive Summary of the Literature Review (2004)

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: Analysis of the CSFII data indicate that NSLP participation is associated with higher mean intakes of food energy and of many nutrients, both at lunch and over 24 hours. NSLP participants are more likely than non-participants to consume vegetables, milk and milk products, meat products, both at lunch and over 24 hours. It should be noted that the relationship between changes in program participation and dietary quality is impractical to quantify, because of the conceptual difficulty of attributing population-wide changes in diet quality to specific influences. The School Meals Initiative for Healthy Children has reduced the fat and saturated fat content of school meals without compromising the overall nutrient content. Only 3.5 percent of all students who submitted an application for meal benefits had an administrative error in the processing of their applications.

Evidence: Children's Diets in the Mid-1990s: Dietary Intake and Its Relationship with School Meal Participation - January 2001; School Nutrition Dietary Assessment-II - April 2001;Regional OFfice Review of Applications (RORA)-2005; ERS' Effects of Food Assistance and Nutrition Programs on Nutrition and Health - Volume 4, Executive Summary of the Literature Review (2004). FNS has an active research program to assess the effectieness of program operations. Results of FNS-sponsored research and evaluations are posted at www.fns.usda.gov/oane. ERS reports are available at: www.ers.usda.gov/publications.