Insight: A Rule Works When Students Eat the Meals

Insight: A Rule Works When Students Eat the Meals

USDA’s proposed rule for school meals is expected to become public this month, opening a period of debate and comment before a final rule now projected for Fall 2027.

The rulemaking is intended to translate the 2025-2030 Dietary Guidelines into revised requirements for federal child nutrition programs, including school lunch and breakfast.

A new Carver Center report, School Meals Examined: A Rule Works When Students Eat the Meals, starts from a simple premise: school meals are already nutritious, and the next rule should build on that record with nutrition, feasibility and participation considered together.

USDA research has described lunch at school as “the most nutritious” meal of the day. A nationally representative analysis found that by 2017-2018, food obtained from schools showed the highest average diet quality of the major food sources studied, ahead of grocery stores and restaurants. A 2024 analysis found the gains after the 2010 standards across every income and racial group examined.

The Carver Center’s report treats nutritional standards, operational feasibility and participation as connected. A standard can produce a nutritional gain only if schools and suppliers can deliver it and students choose the resulting meal.

That is why the report applies four guardrails to the coming rule:

• What authority permits it? 

• What measurable nutritional gain does it add? 

• Can schools and suppliers deliver it? 

• Will students still eat the meal? 

The last two are not implementation details. They determine whether an improvement written into a regulation reaches a student at all.

The report also identifies six issues likely to shape the rule and treats them as fault lines: sodium, whole grains, added sugars, protein, milk and processing classification.

Some are familiar. USDA has adjusted sodium and whole-grain standards repeatedly since 2012, and the added-sugar limits adopted in April 2024 are still phasing in.

Others are newer. Congress changed federal school milk policy in January, expanding the fluid milk options schools may offer. Protein raises questions about how the Dietary Guidelines’ emphasis on more protein and greater variety should apply when districts remove entire categories of otherwise allowable protein foods on fixed days.

Processing is different. Federal school meal rules have principally focused on what a food provides and how it credits toward the meal pattern. A potential processing standard could add a second test based on how a food was made, even when the product already satisfies federal crediting and nutrition requirements. If USDA proposes that kind of eligibility test, the report asks what authority permits it and what measurable nutritional gain it adds.

Participation is a critical part of the school meals discussion. 

Average daily participation in school lunch fell from 31.8 million in fiscal 2011 to 29.6 million in fiscal 2019, while public-school enrollment rose by 1.3 million. The decline was more than accounted for by USDA’s paid category. Several other policy changes took effect in those years, so no single cause can be assigned. But participation cannot be treated as incidental to nutrition policy, and it has not returned to its fiscal 2011 position relative to public-school enrollment.

The broader picture of children’s health deserves the same precision. The federal survey behind the widely cited figure that 40.6 percent of children have a chronic condition includes conditions ranging from allergies and asthma to anxiety, ADHD and learning disabilities, and the survey itself has changed over time. The same survey finds caregivers rating 89.9 percent of U.S. children in excellent or very good health. The report cautions that health problems are not uniform, and a national meal rule should be built carefully to avoid unintended outcomes.

USDA is writing the new rule as requirements adopted in April 2024 still are phasing in to full effect. The next rule should improve a meal program that has already produced measurable nutritional progress, and the rulemaking record is where each proposal gets tested against the law, the nutritional gain, the ability to deliver it and whether students will still eat the meal.