“Wilma:” New School Meal Regs Mean Less Scratch-Cooking, More “Empty Calories”

I hope I’m not exhausting you with posts about the new school meal regulations, but these rules impact the diets of millions of American children every day and seem worthy of in-depth discussion on any blog devoted to “kids and food.”

Today I want to share an excerpt from an email I received from “Wilma.”  (For newcomers to The Lunch Tray, Wilma is an anonymous school food professional somewhere in the United States who contacts me from time to time with her views about school food from “behind the line.” )  I wanted to share her concerns about the new regulations, concerns which in many ways echo those of Justin Gagnon, CEO of Choicelunch (a private school meal catering service), whose views I shared in an earlier post, and those of school food reformer Dana Woldow.   Here’s what Wilma had to say:

One last point I feel like is critical: calorie requirements for each age/grade group. I personally think that the calories are fairly reasonable, but the problem is the students don’t select everything that is offered.

The other challenge is where the calories are coming from. We have to limit the grains/meats (great sources of calories) and increase vegetables that typically run 20-80 calories per 1/2c serving (and are not as desirable to the students). We are finding ourselves back in the “nutrient standard” issues of finding calories. More empty calories will be creeping back into the menu. Jello (the only regs are for fruits/juices with added sugar, not extras!), baked chips (don’t count as a component), imitation cheese sauce (because real cheese sauce counts as a meat/meat alternate and we cant afford to put any more of those on the menu and still meet mins/max)…I actually had a broker come in and bring some dessert treats that shall remain nameless that do not contribute to the grains… therefore are not regulated by the grain-based dessert rule and a great way to add calories to the meals without going over the ranges.

Don’t get me wrong, these regulations in THEORY are great! But I have to agree with your friend Dana and say that some of the creativity of menu planning has actually been taken away because of the new regs. It took me a few weeks into school before I could bring back the “chipotle-like” meal line (with lots of fresh veggies). I’d love to do things like soup/salad or sandwich/salad combos but the regs are very difficult to maneuver. I find myself in a position many other menu planners are in: find the processed food item that fits the requirements. It’s a lot easier than trying to get scratch recipes to work in the new world of menu planning.

So there seems to be a consensus (among these experts, at least) that the new rules may get in the way of schools trying to offer more scratch-cooking and menu variety, and there’s a worry that more processed food will be used since it’s always easier to shoe-horn processed products into such a highly regulated scheme.  That’s certainly troubling, and I’m wondering if it will be possible to tweak those rules before their next major overhaul — something that took 15 years to accomplish the last time around.

I also wanted to share input from another school food professional, Maggie, who often comments on The Lunch Tray.  Maggie took the time to answer my question about this notion, widely reported in the media, that kids can now take unlimited fruits and vegetables if they’re still hungry after the meal.  Maggie wrote:

Bettina, just got a USDA fact sheet today and here’s one paragraph from it:

“Also, there are no specific maximums on fruits, vegetables or milk. Schools may choose to allow greater than the required minimums by offering self-serve salad bars or allowing second servings of these components. Additional servings do count toward the weekly calorie limits, but because fruits and vegetables are generally lower in calories, they can be excellent sources for satisfying meals and sustained energy.”

It isn’t a requirement, but the schools “may”.

I wanted to add the comment that the meal programs have never (to my knowledge) been an all-you-care-to-eat program, and even under the previous regulations and offer vs serve, students would not have been able to choose extra of their favored items as a substitute for others, or always be able choose more than the planned meals/menus.

I think Maggie’s last paragraph is important.  Some media reports have contrasted the new “stringent” calorie caps to the “good old days” when kids were taking unlimited amounts of pizza and fries (without actually paying for a second meal) to satisfy their appetites.  That really didn’t jibe with my understanding of the old system and Maggie seems to confirm this.

Finally, here’s a relatively favorable news report on the school meal regulations which aired last night on Houston’s ABC News affiliate.  I appear in the report toward the end.  And if the reporter hadn’t promised I’d only be shot from the waist up, I might have actually tucked in my shirt and worn something on my feet other than flip-flops!  :-)

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  1. Michelle says

    I think the regulations — old and new — have always hindered but not prevented from scratch cooking. Standards, while they have their use, lay the groundwork for anything coming out of a labeled box being the default. However, rather than ditching standards, it would be great if innovative chefs, partnering with dieticians and fancy software, would collaborate to create recipes that are equally easy to implement and fail safe in meeting standards/regulations. In an ideal world, this collaborative effort would occur ahead of a new rule but even in our imperfect situation, it can be done. I would imagine that handing a food service director a cookbook with recipes that met all requirements has the potential to replicate the ease of labeled boxes.

    • says

      It seems as if it should be simple, Michelle. Get an innovative chef partnering with a dietician and using fancy software, and come up with something awesome that meets the regs.

      I have all of that. Innovative chefs (multiple) working with nutrition experts who know these regs backwards and forwards developing recipes in a scratch environment, and it’s nearly impossible to get everything to balance AND put out a product that parents are willing to pay for and kids will eat. So is the problem that we’re not innovate enough? Or that the regulations are written in a way that actually stiffle innovation?

      I agree with Wilma – the regs in THEORY are great. But they botched the execution – particularly with the grain/protein min/max. Notice how very few people “in the know” with the regs are complaining about increasing fruits and vegetables? That’s not where the problem is.

      • Michelle says

        I fully agree that the standards can be stifling and encouraging the use of processed foods. What do you suggest is the answer? I ask this because I’m really curious and not being snarky! I cook my family meals from scratch mostly and I have no idea if I’m actually providing balanced nutrition for my kids. I would hate to have to use nutrition software to do it! :) So I ask because I really want to know the answer so that, as a parent advocate, I can fight for something that is attainable.

        • bw1 says

          “I have no idea if I’m actually providing balanced nutrition for my kids.”

          Educate yourself, and add a dose of common sense. One good litmus test is, if you never make your kids eat something they don’t like, you’re probably missing the mark. Our basic instinctual tastes were formed by the evolutionary pressures on our hunting/gathering forebears, who typically traveled 10-20 miles a day on foot in search of food, and didn’t have have surpluses or much grain. Those tastes don’t translate to a healthy diet in an less active industrialized society. People can learn healthier preferences, but such habituation takes far more exposures (more than 10 per new food) than kids willingly undertake.

          That’s why, unless parents do the hard work of teaching their children that eating is not merely a means to pleasure, but a life sustaining function, menu regulations will never do more than control to what sort of water the horse is led.

          Top down regulations like this always suffer from unintended consequences, they are the way government operates, and are this is the pitfall of handing your children over to the government, even part time.

        • Maggie says

          I’m not sure there is any one answer.

          If your are interested in working at your local school, it might mean finding out what is going on currently. What changes, if any, are they working toward? If there are changes that you feel would be beneficial, are they possible right now and if not, what would it take to make those changes (for example, you mention the creation of recipes, but perhaps there is already someone on staff very capable of creating the recipes, but the school kitchen doesn’t have the equipment or staffing hours to cook the food).

          I apologize, I don’t know if you’ve been following Bettina’s blog for sometime, if you have heard her mention Dana Woldow? She has written numerous excellent articles about realistic approaches to making improvements and working as a school meal reformer.

      • Maggie says

        I agree that getting better food to students, teaching students about food/nutrition…all of that is great! How to accomplish it is the hard part.

        I know I’m repeating here from previous posts, but, sadly, there are schools without on-site kitchens, for example, which means that recipes and outside input are not the stumbling block. There are just so many different situations out there! (and that is something that, even though I work in school food, I just started to realize in the last couple of years!)

        The minimums and maximums are a bit of a challenge (understatement). More than one choice of main dish on the menu for the day and it is a crazy juggling act to be sure that no matter what the child chooses, that you have not gone over or under the requirements for the day or week.

        And, another point that is outside this particular discussion of the regulations, but one that bothers me… Even if these new regulations turn out to be perfect and the food is all wonderful…lets not forget that likely the students are gulping it down in 5 to 10 minutes, in a crowded, loud, cavernous room. There need to be changes beyond the food itself if we are going to make a real difference.

  2. says

    Bettina, thanks so much for the insight that this post provides and to Maggie and “Wilma” for their input as well so that we can hear other sides of the story. School food, and the changes that are being made, is such a huge mountain to climb that it is helpful to have the tools and information parents like me need to provide to our own schools so that they can better understand the big picture as well.

  3. Maggie says

    I should be sure to clarify that I can only speak from limited experience with only the district that I work for.

    For example, while we didn’t offer free additional servings of pizza or fries, in the high schools, had a table/serving station with bread, peanut butter & jelly where students could make sandwiches…free of additional charge, with their meals. With the bread/grain and protein caps, that is not offered anymore.

    I would guess that any extra offerings which may have been offered elsewhere in the past depended on the finances of the district and/or if the program was self-operated or contracted.

    There might also have been misunderstandings in the past if the additional servings were actually being paid for by the students, over and above the cost of the reimbursable meal, not being offered free.

  4. says

    Read very carefully what Wilma says about the “empty calories” in the second paragraph. This is real, and it’s a HUGE problem. With protein and grain min/max, menu planners are incentivized to find those “empty calories” that they otherwise would have filled with lean proteins or whole grains.

    What the USDA SHOULD do is eliminate the protein and grain min/max. However, what they likely to do if they want to close that loophole is just add MORE regulation to it to lock it down even further, making it even harder to comply with already restrictive regulations.

  5. says

    This is SO right on!
    Yes, the empty calories are real and food manufacturers ARE scrambling to prove how little meat and grains they are now able to show in their nutritional labels. One way to get more calories without protein (meat) and carbs (grains) is with fat. Yes, there have long been limits on fat and saturated fats, but many of our nation’s manufactured foods have been touting low fat for years. Flavor comes from fat and salt, largely in our conditioned American palate. With the very strict sodium limits that loom in the next few years, food factories are inevitably going to be going pumping in fat (maybe 20% to the range 30% range allowed by the USDA). Afterall, 100 calories of fat is a heck of a lot cheaper than 100 calories of fresh vegetables and if there is anything these regs most sorely need to do them justice, it is funding.

  6. Coleen Donnelly says

    I am a chef who has worked in school lunch reform for over 10 years. I currently work with a whole grains company developing scratch cooking recipes that address the unique needs of schools. It is true that not all kitchen scenarios are alike, so it is my job to offer support to all models. From a district in which each school batch cooks for its own students to a central kitchen serving 14,000 meals using only a 400 gallon steam kettle to the nation’s largest district in which many schools are self-op and without highly skilled staff members or adequate equipment, I have to understand their needs and provide solutions. As different as each district is, the directors are equally as diverse. The grain maximums have unintended consequences that are causing even the most progressive directors to give in to the whole grain pizza crusts and hamburger buns and forgo more nutritious whole grains in an effort to maintain participation.
    It is complicated beyond belief, but as long as we keep the conversation going and push for scratch cooking solutions we will see playing field continue to level. Hopefully, the protein and grain maximums will be re-evaluated in a way that allows for more variety and choices.

    • says

      You hit the nail on the head that the maximums should be re-evaluated in a way that allows for more variety and choices. As Maggie said, once you offer more than 1 entree a day (we do 16 a day, if you can imagine, with over 75 possible entrees in a month!) the complexity of making everything fit and comply is nightmarish!
      Yes to keeping the conversation going, not just here, but where they are writing these rules too! I followed these HHFK Act changes from 2010 and even I totally missed the ‘minimums and maximums’ until the April 2012 Q and A clarification posted by the USDA. Was I the only one that grasped this late last Spring?

      • Wilma says


        I didn’t see the mins/maxes during the open comment period, otherwise I would have put my 2 cents in. I also didn’t get a straight answer on how to measure them until the summer.
        I would like them to re-open comments and revisions now that menu planners/directors/managers have had an opportunity to really feel out the rules.

        Bless you for offering 16 choices daily! I can only imagine!!

  7. Maggie says

    Until the regulations were officially in place, I suppose it would have been possible to try to envision how it would all work out & what would cause issues, but it would have taken some looking into the future and guess work. For example, would we first plan our menu under the old regulations, and then take the time to create new recipes or assume new product developments to figure out how they’d fit the proposed (and changing) new regulations?

    What I’m saying is, that even if we would have tried to guess how we would change the menus to meet, for example, the bread/grain min/max, we would not have known exactly what specifications our products would have once our suppliers started to change for the new regulations.

    I’m trying hard to remember the very first information sessions we attended about HHFK act. I don’t recall the min/max coming to my immediate attention.

    I do recall there was encouragement to start to make the changes that could be made under the old rules, if you were not doing these things already, such as focusing on introducing more of vegetable groups that one might not have been offering, changing the varieties of milk being offered.

    By the way, I’ll stop feeling sorry for myself when I’m only trying to juggle a k-5 menu and a few choices each week. :-)

  8. says

    the unintended consequences of the regs and changes is maddening. why is there no solution that actually nourishes school kids? instead IOM and USDA try to “help” which is really just creating monsters that need to be tamed and mitigated by school food directors? then stupid stuff happens like nutrient void jello with brain harming food dyes and animal crackers that count as calcium because of fortification.

    the real solution is to offer kids real food. yet the regs encourage more school directors, even the ones who KNOW what the right thing is to make retarded compromises that harm kids. *bangingheadrepeatedly*

    • Maggie says

      I might be way off base on this, but, there’s simply so much behind all these discussions.

      It seems simple enough to say “give them good food”. But, who is going to choose what “good food” means? Food is such a personal thing, so many things enter into it when considering what is “good food”. Local food? Dye free food? Organic food? Non-processed food (I noted that the unprocessed food challenge had a 30+ page document to determine the basics of defining unprocessed)? Then figure in culture, geography, and more.

      (In Brian’s post about his school’s meals in a recent post, his comment about the students happiness with cheese grits. If there was a sudden change to regulations to require grits, my students here “up north” would wonder what in the world we were serving them!)

      Since it is a taxpayer supported program, there probably does need to be some accountability about the monies that are spent. And, I know, the whole idea that it is a government operated program in the first place brings up a lot of questions & concerns (should the program even exist, what about the influence of lobby groups, and on and on).

      So, I suppose, the regulations, in theory, try to be broad enough to allow for individualization, narrow enough for everyone to be treated fairly, and work for the little school in a very rural, isolated area or a huge metro area.

      My apologies if I’ve wandered way off topic here. I’ve wished often enough to have someone say to me – just make them a good lunch and we’ll give you what it takes to make it happen.
      (but then, we are just back at the start of this post, where we try to decide what good really means.)

      *echoing jenna’s head banging*


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