How Does School Food Work?


How Does School Food Work? 

More and more schools are working to make food healthier – putting more focus on salad bars, making vegetables appealing, and introducing plant-based entrees. While school meal regulations that were updated in 2012 were intended to make school meals healthy, most school meals still are not. Schools must offer vegetables, fruits, and at least some whole grains, but that doesn’t mean those items are on a child’s cafeteria tray. A cheeseburger on a bun that is only 40% whole grain with a carton of apple juice (100% fruit juice can count as a fruit half the time) can count as a “meal” which is eligible for reimbursement from federal and state governments. Because it meets the federal regulations, many claim this is a healthy meal. 

School food is a business, and the focus is obvious when attending professional conferences for food service workers. The expo floors have very few healthy foods: meat and cheese entrees and refined grain products that are 50% or less whole grain take up the vast majority of the show floor.

You can learn more about school food trends and statistics here


These are the required components of school lunch:



The vegetable category must include the following at least once each week: greens, orange/reds, legumes, starchy, and other. These can be fresh, frozen, or canned. Legumes can also be served as a high protein food (meat alternate). “Other” can include things like cauliflower, cucumbers, eggplants, or other veggies that don’t fit in one of the other categories. Greens, orange/reds, legumes, and starchy vegetables offered a second time in a week can count as “other”.


Fruit can be fresh, frozen, or canned. It may have sugar added, and this is common for canned and frozen fruits offered in schools. USDA federal regulations allow 100% fruit juice to count as a fruit half the time, however a school district does not have to allow this. In New York City, while fruit juice is offered, it does not count as a fruit serving.

High Protein Foods (Meat/Meat Alternate)

This is one of two categories of food most in need of improvement. Typically meat or cheese is offered. Plant-based options are being requested more and more. “Meat alternates” include (but are not limited to) beans, lentils, split peas, tofu, tempeh, soy yogurt, and some manufactured plant-based protein products, such as falafels and veggie burgers. You can find scratch-made plant-based meat alternate recipes in our recipes section. While soy yogurt is allowed, it is not affordable for schools.


Grains must be 80% “whole grain rich”, which actually means 40% whole grain. The term “whole grain rich” is very misleading. It actually means 50% whole grain. With the roll back of school meal standards, instead of 100% whole grain rich (50% whole grain), grains only need to be 80% whole grain rich (40% whole grain). Another problem with the grain category is that when flour is used, as in the case of breads or pizza crusts, often times there are a number of food additive ingredients, including preservatives.


A variety of dairy milks must be offered, but there is no requirement that schools offer chocolate milk. Non-dairy milks may be offered with a doctor’s or parent’s note, in that case, a school may, but is not required to provide the non-dairy milk. One reason is because it is more expensive and the school does not receive additional reimbursement for it. An exception is that if a student has a plan under Section 504 of the Rehabilitation Act. You can read more about how schools must accommodate students with disabilities here. In this case, if the plan says the student must have non-dairy milk, then the school is required to provide it. This is a civil rights law and protects students with disabilities from being discriminated against.

This chart shows the required components of the school lunch:

Chart showing the Lunch Meal Pattern for the USDA School Program

This chart shows the required components of the school breakfast.


USDA Chart Showing the Breakfast Meal Pattern Requirements

Below is an image of a typical breakfast that we have seen in schools. However it does not meet the USDA regulations that restrict juice to no more than 50% of the one cup “equivalent” of fruit that is offered at each breakfast. This breakfast has over 50 grams of sugar and is highly processed lacking any whole, fresh food. Without the extra juice, it meets the guidelines because it has juice (for the fruit), milk, a cereal (the grain) and a yogurt (a meat/meat alternate that can stand in for one of the grain servings). 


Water must be available at breakfast and lunch. Water is not an official component of the school meal program. However, it is required by law that schools offer free water. While a water fountain in the cafeteria qualifies as meeting this requirement, we recommend that schools use a water dispenser with a clear top. To make the water appealing to students, add citrus or cucumber slices, or fresh mint.

Self-Op or Contract Management?

In relation to making positive changes to a school menu, an important question to find the answer to is does the school district employ their own food service staff (called “Self-Op”) or do they hire an outside company to manage their foodservice (called “Contract Management”).

In Self-Op schools, there is a Food Service Director who oversees the operations and they plus all of their employees are school district employees. The Food Service Director is in a decision making role and can decide to make changes to the menu. See more information here to learn how to create change in your district. 

In schools that have food service provided by Contract Management, while decisions about the food may come from many different interested parties such as the Wellness Committee, the School Board, the Superintendent, or the PTA, ultimately, it is the Business Superintendent that writes the contract for the foodservice management company. All food service management companies that we know of have the capability to provide vegan meals, especially because they virtually all also service college accounts, where vegan meals are in high demand. That does not mean they automatically offer them in a K-12 school. The only way to ensure that there are vegan main dish meals is to have it written into the contract. In this case, reaching out to the Business Superintendent to find out what it would take to have a requirement to have vegan meals included in the contract is one of the best ways to approach it. If this person is not open to this idea, they can be influenced by others such as having it requested by the school board, the superintendent, or a number of interested parents. See more information here to learn how to create change in your district. 

Offer Versus Serve

Virtually all schools participate in something called “Offer versus Serve”. This is required for high schools and optional for elementary and middle schools. Virtually all schools participate as a way to save money and avoid food waste. That means that the five components of the meal: vegetable, fruit, high protein item (meat/meat alternate), grain, and milk must be offered, but only three need to be chosen to constitute a lunch that the school can receive reimbursement for from the USDA and their state, if their state offers reimbursement.  One of the three chosen components MUST be a vegetable or fruit. 100% fruit juice can count as a fruit half the time (though schools do not have to allow this, for example, NYC requires students take an actual fruit or vegetable). Milk does NOT need to be taken, contrary to what many people believe.

A cheeseburger on a bun that is only 40% whole grain with a carton of apple juice can count as a “meal” which is eligible for reimbursement from federal and state governments. Because it meets the federal regulations, many claim this is a healthy meal. 

From our extensive work with schools, a typical meal is often a serving of the “Meat/Meat Alternate” component (what most of us might call the “main dish”, “entree”, or “protein”), and the vast majority of the time, that is meat or cheese. This meat/meat alternate component frequently includes the grain, such as a burger with a bun, or pizza. Children then only need to take one additional item: a vegetable or a fruit (or fruit juice). 

While the intention of Offer Versus Serve is good, the reality is often a meal that may not be at all healthy. This could change if schools switched to more plant-based “Meat/Meat Alternate” options, and less burgers, pizza, mozarella sticks, chicken patties, grilled cheese sandwiches, chicken nuggets, and deli sandwiches. For example, our Awesome Bean Burger could be served on a whole grain bun, and a piece of fresh fruit. That would meet the Offer Versus Serve criteria, and would be pretty healthy, although we’d like to see the students take the vegetables too!  

USDA Foods (Commodity Foods)

USDA Foods used to be called Commodity Foods. These are foods essentially given to schools, however the schools do have costs associated with transportation and storage. The name was changed to upgrade the image of “commodity foods”, because commodity foods used to have a bad reputation. While there have been efforts made to improve the quality and variety of USDA Foods, there are still plenty of USDA Foods that really have no place in schools.

A common misconception is that USDA Foods are excess foods “dumped” on our nation’s children. But actually, that’s not true. The foods are grown or raised at the request of the federal government for schools as a way to support agriculture in the United States, and therefore, all USDA Foods are all grown or raised in the United States. They are a mix of foods that are healthy and unhealthy. You can see the most recent list here.

There is a type of USDA Foods called “Bonus” Foods. These are foods that there are excess of, that the government purchases, and which schools may obtain. But the Bonus Foods are not “dumped” on schools. The USDA, via the state education departments, lets schools know when there are Bonus Foods available. Schools may order them, but they are not forced on the schools. Bonus Foods can be healthy as well as unhealthy. Years ago, there were unsweetened frozen cherries available. Bonus Foods have not been available for several years now.

USDA Foods can be shipped directly to the regional storage where schools can access them, or they can be diverted for processing. So for example, a school can order chicken to be diverted to be processed into “popcorn chicken”.

Healthy USDA Foods: canned or dry pinto beans, brown rice, fresh potatoes, frozen broccoli, fresh apples, and frozen unsweetened wild blueberries.

USDA Foods That Contribute to Disease: smoked turkey deli ham (processed meats are known human carcinogens), beef products (probable human carcinogens), cheese (a major source of saturated fat in the diet, even reduced-fat and part-skim are still high-fat foods, for example, low moisture part-skim mozzarella, commonly used in schools on pizza, is 62% of calories from fat, even though “part-skim” would lead us to believe that it is low-fat), eggs (even the FDA says they can’t carry a claim of being healthy), and white flour (contributes to overconsumption of calories and diseases caused by diet).

Problems with USDA Foods:

  • Schools can not necessarily order whatever they want from the USDA Foods list. Enough schools in a region must want that food to warrant bringing a whole truckload to the area. A school wishing to obtain USDA Foods brown rice may not be able to if enough other schools in the region don’t order it.
  • Over 40% of USDA Foods are diverted for further processing. Generally speaking, those foods become highly processed foods. These highly processed foods then become competition for healthier choices.
  • Schools rely on the meat and cheese to make their “meat/meat alternate” component of the meal. Schools might not order as much of the healthier items because since the food is essentially free, schools are going to order what would cost them the most on the open market.
  • Schools are challenged to offer healthier options due to having to use the USDA Foods that they get. For example, if a school wanted to offer a hot cereal bar at breakfast, they couldn’t justify (from a financial perspective) ordering a variety of fresh fruit when they already have canned peaches with added sugar and frozen strawberries with added sugar. This is a challenge for Food Service Directors who want to do the right thing and feel like they are between and rock and a hard place.
  • School meals are supposed to be consistent with the US Dietary Guidelines. The problem with this is that the US Dietary Guidelines are problematic for all people, but even more so for people of color. You can read more about “Racial Bias in the US Dietary Guidelines” here and here.

Solutions to Challenges:

  • At some point in the past, in some states, schools were allowed to take the dollar value of the commodity foods, instead of the commodity foods. I have heard Food Service Directors who wish they had this choice.
  • Continue to improve USDA Foods, and eliminate the foods that contribute to disease. Why should we be feeding food to children that is not healthy for them in a place where they go to learn? And why should these unhealthy (or less healthy) foods be paid for by our tax dollars? Let the food in schools be health supporting and disease preventing.

Budgets and Reimbursements

Schools participating in the USDA school meal programs receive a reimbursement for meals that are free, reduced price, and even for paid meals. This chart shows the reimbursements for the 2021 – 2022 school year. Note that as of now, through the end June 2022, all school meals are free. Many advocates are working on legislation, introduced by Senators Bernie Sanders and Kirsten Gillibrand to keep school meals free, which eliminates stigma and dramatically reduces administrative work which is takes time and dollars. 

A chart showing the reimbursement rates for free, reduced price, and paid lunches and breakfasts put out by the USDA for 2020 - 2021

Community Eligibility Provision

The Community Eligibility Provision (CEP) is a non-pricing meal service option for schools and school districts in low-income areas. CEP allows the nation’s highest poverty schools and districts to serve breakfast and lunch at no cost to all enrolled students without collecting household applications. Instead, schools that adopt CEP are reimbursed using a formula based on the percentage of students categorically eligible for free meals based on their participation in other specific means-tested programs, such as the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF).

This chart shows what schools in each state are eligible for the program.

The Problem of Too Many Choices

It is really clear to us that one of the biggest challenges to getting students to eat healthier food at school is that there are too many choices. We would have no problem with this if all of the choices were healthy choices. But when one of our plant-based entrees is up against six other choices, the chances aren’t so good that the plant-based option will be taken by a majority of students. And yet before the “new” requirements for school meals came into being in 2012, we were serving two or three plant-based meals per week in five New York City schools. And while students could choose PB&J or cheese sandwiches, usually they were out of site and the vast majority of students were not only taking our entree, but eating it too. I will never forget walking into a school and watching about 475 (over a few lunch periods) children enjoying North African Gumbo. We promoted it by having all the ingredients on a cart and traveled table to table to show the students what was in their food and they very much engaged in seeing, touching, and smelling the ingredients.

Why Can’t My School Offer “X”

So many people contact us and ask why their school can’t offer guacamole, soy yogurt, non-dairy cheese, fresh berries, or other expensive items. Thse are just a few examples. There are two reasons for this:

  1. The school meal budget does not provide enough funds for items such as avocados (this may not be an issue in California), soy yogurt, non-dairy cheese, or fresh berries (it’s true that a school may be able to offer any of these on rare occasions).
  2. Non-dairy cheese does not “count” as anything. It doesn’t have enough protein in it to count as a meat alternate, and therefore it doesn’t fit into any of the components (see the images and descriptions of components above). While protein is not a nutrient of concern according to the US Dietary Guidelines (despite all the marketing for high protein items), a certain amount is still required in the school meal programs. That’s because while most people will get enough protein if they get enough calories, there are many children coming to school who live in food insecure households and so it is important that the children get enough calories and nutrients at school. Because of this, it’s also really important that the food served in schools be nutrient dense, unprocessed, and healthy. We say “Hungry Kids Need Healthy School Food”.

Plant-Based (Vegan) Meals

 The research is clear. The more plant-based we eat, the healthier we’ll be. Healthy, whole plant-based diets can reverse heart disease without drugs or surgery, can dramatically lower cholesterol and blood pressure in weeks, can reverse type 2 diabetes in just a few months, reduce the risk of cancer and can extend cancer survival time, help many autoimmune diseases, and lower the risk for Alzheimer’s Disease. If you change your diet to address any of these health issues, please be sure to let your health care provider know before you start as your medications may need to be lowered or eliminated. For example, diabetics could end up in serious trouble (or worse) if they are not closely monitored during dietary changes to have their insulin levels modified. 


Aside from milk, which is required to be offered but IS NOT required to be taken, the food itself can be entirely plant-based. There is no requirement for schools to serve meat, cheese, eggs, fish, or seafood. Since three out of the four food categories for lunch are naturally already plant-based: vegetables, grains, and fruits, we focus more (but not exclusively) on the “meat/meat-alternate” category of the meal. 


To qualify as a plant-based “meat/meat-alternate”, schools can choose from the following:


  • 1/2 cup beans, lentils, or split peas
  • 4.4 ounces of firm or extra firm tofu
  • 4 Tablespoons peanut or other nut butter
  • 6 ounces of soy yogurt (however, we aren’t aware of any school that offers this, or can afford to offer it)
  • 2 ounces of tempeh (this just became allowed as of June 2019
  • Other products such as American Bean Products Falafels which carry the “CN” (Child Nutrition) label. This is a designation for foods that do not easily fit into one of the previous categories. 


 Our Recipes are approved for use in schools (they meet the USDA School meal guidelines as a meat/meat alternate).  


Non-Dairy Milks

Non-Dairy Milks are one of the fastest growing food/beverage trends in the country and world. Many people are choosing not to consume milk due to health, environmental, ethical and social justice considerations. Some of the health considerations include lactose intolerance, which is the norm for the majority of the population, which can cause diarrhea, bloating and pain; dairy allergies, which can cause chronic constipation in children; prostate cancer, which milk and dairy products are linked with.


Schools may, but are not obligated to provide non-dairy milk to students with a note from parents/caregivers or a doctor. The reason schools are not obligated to is because a serving of non-dairy milk costs nearly as much as the entire food budget for the lunch meal (five components of food). For students with a special dietary plan under the American’s with Disabilities Act, schools may be required to provide non-dairy milk when requested by the child’s doctor. 


Schools may offer non-dairy milk as one of the varieties of milk. However, we aren’t aware of any school participating in the USDA school meal program that does this – and the reason is because of cost. Schools would probably need to do special fundraising to be able to offer non-dairy milk, or receive additional funding from the school budget, which does not normally help to cover the school meal program budget (the school meal program budget is “self-supporting” and comes from federal and state reimbursements, paid meals, a la carte sales, and catering, not from the school budget that the community votes on). 



Lunch Period Timing and Length

The USDA regulations state that school lunches should fall between 10 am and 2 pm. However schools can also get exemptions. It is very distressing that some students are having their lunch periods at 9:30 am! This is likely to happen due to the size of the school and the number of lunch periods required to get all the students through the lunch room. But it is unacceptable.


The other major problem is that students often don’t have enough time to eat lunch. Lunch periods are often scheduled for 1/2 hour. But that includes time to get from their classroom to the lunchroom, stand in line, get to their table, and then eat. And often children are busy socializing with each other now that they have some down time away from their class work.


Together, these problems result in children who are hungry part of the day and a lot of wasted food. Hungry children can’t focus and do their best in school either. It’s not that the administrators don’t care. Cafeterias can only hold so many students at a time. And student schedules are often the result of mandated classes that have to be fit in. Most people agree, including the decision makers in the schools with these challenges, that this is a huge problem.



Recess before lunch is an important way to make sure children are hungry and ready to eat. By going to recess first, they get their socializing and they are active, so by the time they come in they are hungry. Advocates should encourage their schools to hold recess before lunch. Scheduling issues can complicate this, but since some schools have found a way to do it, it must be possible.