A Deep Dive Into the School Lunch Program

By Lisa Du

As an example for you, we examined two school districts in depth: Brownsville, TX and Hutto, TX.  Though we did not find clear, smoking-gun evidence of program failure in either case, the steps we took and the questions we asked will help you understand how to evaluate your own school district’s lunch program.

Background

Brownsville Independent School District in Brownsville, Texas had a total student population of 49,879 students in October, 2010. The district, which is relatively poor, has 52 elementary, middle, and high schools. The city of Brownsville is 92.3% Hispanic. According to the American Community Survey, the median household income in the area is $28,929–at about the usual cutoff for free lunch. Overall, 33.9% of families live below the poverty level.

Brownsville school district had one of the highest NSLP spending-to-pupil ratios of all Texas school districts in the 2007-08 fiscal year. The district reports that it spent $24,284,000 in federal nutrition dollars for the year, but the district reported only 238 students registered for free lunch and 12 students registered for reduced-price lunch, according to the Common Core of Data compiled by the Department of Education. Divided out, the federal government is spending $97,919 per child in Brownsville.

Provision 2

What the Department of Education data didn’t tell us was that Brownsville ISD is under Provision 2 of the school lunch program. Brownsville has been under Provision 2 and serving free lunches and breakfast since 1992, said Terry Mendez, Brownsville’s food and nutrition service administration chief. Provision 2 allows a school district to get its reimbursement for “universal registration” when the poverty rate is high enough.

Under Provision 2 of the lunch program, the school district uses counts during a single year to set percentages of students who are eligible for free, reduced-price or full-price lunch. This is the “base year.” For the next 3 years, all schools in the district only need to count how many meals they serve each day (rather than how many meals at each rate they serve each day) and provide monthly counts to the state agency. The district is reimbursed according to the percentage of students buying lunch at each rate in the base year.

If there is a difference between what the district spends on lunch and the federal reimbursement, the district must use its own money to cover the cost of the lunches. This risk highlights the fact that few schools have the incentive to invoke Provision 2, unless they believe that the base year reimbursements are more than they will need, or unless the administrative burden of checking student eligibility and counting types of meals each day is too much.

Jessica Saracino, a program analyst in the U.S. Department of Agriculture, says most schools choose to go to Provision 2 lunch when there is a very high level of poverty in the area, as in Brownsville. This is because, despite the risk that they would have to pay the difference between their spending and the federal reimbursement, most of them are willing to take the chance. Because Provision 2 allows the school to use the same free, reduced-price, and paid lunch percentages for 4 years, the decrease in paperwork and overall administrative duties will allow the school extra profit and money to pay off the difference in costs, Saracino added. In addition, Mendez added that the Brownsville ISD food service also uses profits from a la carte items not part of the traditional school lunch menu.

Saracino also could not provide an explanation for the numbers reported by the Common Core of Data. The error may have arisen out of the lack of collaboration between the U.S. Department of Education and the USDA.

Accountability Issues

Brownsville is an interesting case study of the National School Lunch Program, and as an example of how universal free lunch works. However, there are many accountability holes in Provision 2.

First, the reimbursement for the three non-base years depends solely on lunch counts, and there is no way to check for miscounts (human error) or fraud, which could increase the lunch count and allow the school district to receive more money than necessary. The only standard against which they can measure the lunch count is the number of students enrolled in the district; it could be suspicious if the school consistently reported an extremely high percentage of students attending school and buying lunch. In addition, the records of the amount of commodities could be used to gauge whether the lunch counts are correct, but the state does not require records for food purchases and lunch production, although School Food Authorities are supposed to keep them.

The percentages of free, reduced-price, and paid lunches are fixed for 3 years after an initial base year of gathering data. If there is a large amount of human error or the percentage of free lunches is purposely altered, the difference between projection and reality would also be extremely hard to track because applications with family income and tax information for free lunches are kept private. In addition, a USDA study found a 3.9% average error rate in certifying a student as qualified for free or reduced-price lunch.  Seventy-eight percent of those students were approved to receive more benefits than they deserved.

Furthermore, although the policy states that schools must reset their base-year percentages every 4 years, Mendez said Brownsville legally used its 1992 percentages until the 2005-06 school year, because the Texas Department of Agriculture offered them that option. Using the same percentages for free, reduced-price, and paid lunches without regular reporting, given the usual level of error, will likely create a big spending problem over the course of a decade.