This is a guest post about proposed changes to the National School Lunch Program, written by Leah Dillard, a mother of three living in NW Arkansas.

Okay guys, this one’s worth reading. It’s the proposed changes to the federal school lunch program, published January 23, 2020.

If nothing else, please read the actual 41-page pdf of changes. Or just read #3,#5 & #7 in this post, and then submit your comments to the USDA. Basically they’re privatizing the school lunch program, making us pay 4 times for it, and changing the meal requirement to be only 1.5 cups of lentils — like, for the MEAL. In lieu of breakfast, and then in lieu of a meat, green veggie, & red veggie at lunch… 1.5 cup of lentils will count as all that.

I had to dig through the FDA website to find the actual proposed changes, and they are:

#1) These changes would make money more important than nutrition, when evaluating school lunch programs.

Compliance with Performance Standard 1 areas is critical to ensure Program integrity. It is inconsistent to require State agencies to review SFAs [School Food Authorities] early in the review cycle only when there is significant noncompliance with the Performance Standard 2 meal pattern and nutrition requirements, and not for Performance Standard 1 requirements.

Pg. 4098: Federal Register / Vol. 85, No. 15 / Thursday, January 23, 2020 / Proposed Rules.

This paragraph tells states to audit SFAs based on Performance Standards 1 (children’s eligibility, certification, meal counting/claiming requirements, and profitability) & 2 (actual nutrition) at the same time.

So checking if nutritional requirements are being met will automatically trigger an audit of eligible students. The auditor will be a private corporation, paid by our state. They will be able to cut students from the school lunch program based on old federal records, instead of current federal income review.

#2) These changes would empower states to hire private companies (with state tax money) to manage the federal program.

Pg. 4098: Federal Register / Vol. 85, No. 15 / Thursday, January 23, 2020 / Proposed Rules.

Private auditing companies could use old federal data to determine a child’s current lunch eligibility. We would pay those companies tax incentives to do so, out of our state tax budget — not the federal budget responsible for the program.

It goes on to declare the federal government not responsible for errors this causes (such as accidentally removing & starving a child.)

The administrative review ensures that SFAs process applications and verification documents correctly, but it cannot confirm the underlying accuracy or completeness of applicant reporting.

Page 4099: Federal Register / Vol. 85, No. 15 / Thursday, January 23, 2020 / Proposed Rules.

So we’ll be paying & subsidizing private companies to do a job we know beforehand that they have no way to accurately do.

#3) So, if your school has a lunch budget deficit, these rules instruct them to hire an outside, private company to audit which all children can be knocked off the program, without actually verifying current family income eligibility. Our state taxpayers will have to finance both the ‘audit’ & the tax incentives to the auditors — and no one has to verify if it’s correct.

#4) All that’s only a description of one of the titles from two full PAGES of titles of program changes.

#5) Instead of 5 distinct food groups, a serving of lentils will count both as a meat & vegetable.

Page 4103: Federal Register / Vol. 85, No. 15 / Thursday, January 23, 2020 / Proposed Rules.

That may not sound big, but on a child’s actual plate, it changes a serving of chicken & a side of broccoli into a single lump of lentils.

#6) These rules would reduce the number of red/orange veggie servings required per day from 1.5 cups to 1/2 cup, and cut weekly fruit servings in half.

#7) These proposed changes would make the veggie categories interchangeable. So instead of leafy greens being one, red/orange being one, etc.,- all of those can just be lentils now.

School lunch can now be 1.5 servings of lentils, instead of chicken, marinara on spaghetti with a side of broccoli & a green salad with carrots & cherry tomatoes.

#8) We pay four times.

  • We send money to school with our kids.
  • We pay federal taxes earmarked for the National School Lunch Program.
  • We pay state taxes intended for oversight and accountability.
  • We pay extra state taxes to make up the taxes we lost by giving tax breaks to the private companies doing our federal government’s job.

#9) They have buried the request for public comment. (Spoiler alert: You can comment here.)

Buried within the pdf of the program are repeated requests for our input on the program changes.

However, neither the main page, program page, summary of changes, etc., asks for public input – not once – on these massive fiscal responsibility changes, eligibility determination changes, nutritional guideline changes, or change in the definition of the primary responsibility of the food program from providing adequate nutrition to ensuring profit.

Instead, it’s a cute, little 5-line illustrated list, saying the program cuts red tape, and makes it easier & cheaper to reduce food waste.

Well, yes, serving only lentils is cheaper. But no, offering only lentils won’t prevent illness. It won’t build brains & bodies strong enough to build our economy for the future. And it won’t prevent kids from starving.

These proposed changes will take our earmarked “National School Lunch Program” federal tax money, and allow it to be used for other things than feeding our kids.


We already have a “school lunch debt” problem in this country. Even relatively affluent parents can’t afford all the a la carte items now offered as additions and alternatives to the main meal. If these rule changes go into effect, our children will still pay the same price (free, reduced, or full) but receive only lentils. All the kids with a choice will switch to the over-priced a la carte items, leaving the lentils for the kids on free & reduced lunch.

If/when kids still can’t pay, does our tax money go to paying their lunch debt? No. Our state tax money (not the federal school lunch tax money we already pay) will go to privately-owned auditing companies AND we’ll have to pay extra state taxes to cover the tax cuts given to these private companies.

Again, for 1.5 cups/day of lentils. That’s the new food requirement.

Everybody go offer your “public comments” here! The deadline is March 23, 2020.

2 Comments

  1. Re: #5
    There is a note under that chart that says if lentils are used as a meat substitute they do not count as a vegetable. Also for a reimbursable meal at least 1/2 cup of fruit must be served (even under offer versus serve). Please explain your conclusion then that the whole meal could be lentils?

    , “* * Legumes offered as a meat alternate could meet the weekly legumes subgroup requirement. However, legumes offered as a meat alternate would not count toward the daily and weekly vegetable minimums (1 cup and 5 cups, respectively, in the grades 9–12 example above) because doing so could significantly reduce calories.”

  2. Leah- thank you for being the kind of parent that helps educate other parents and who cares for all students, not just your own. You are amazing and this is so important! Thank you!!!!

Comments are closed.