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method might be particularly useful in estimating whether intakes would exceed the Tolerable Upper Intake Levels. Assumptions about the levels of acceptance of the proposed changes by students, participation rates, and the degree of supplementation or substitution resulting from the recommendations will be considered by using a range of values. For many changes, the likely benefits and consequences will be multidimensional, in the sense that several of the key factors will be affected by the recommended revisions. For example, a likely consequence of eliminating flavored milk (i.e., chocolate or strawberry) would be to reduce the intake of added sugars, as recommended by the Dietary Guidelines for Americans. However, another likely consequence would be to reduce the consumption of milk and thus reduce calcium intakes, thereby increasing the likelihood of inadequate calcium intakes. Similarly, a change designed to reduce the prevalence of inadequate intakes might be so unattractive to students that the net effect of the change would be the opposite of what was intended. During Phase II, the committee will review publications that provided data on menu characteristics and other factors that influence meal acceptance by students. The committee will examine the recommendations relative to each of the factors separately and consider qualitatively the net effect of the combined benefits and consequences.

The sensitivity analysis will rely on published studies and reports, when they are available, as well as the experiences of practitioners in the school food service industry. A key type of information will be the experiences of school districts that have implemented changes similar to those recommended in the proposed standards. Whenever possible, the sensitivity of the likely benefits and consequences will be assessed with respect to the uncertainties in the assumptions used to evaluate the recommendations.


Because the U.S. Department of Agriculture (USDA) does not anticipate that additional funding will be available to schools to implement the revised requirements, any proposed revisions to the Nutrition Standards and Meal Requirements used for the school meal programs should be examined with respect to how change may be affected and increases in costs may be minimized. The committee’s intent is to design recommended revisions that will keep program costs economical and as close as possible to current levels (adjusted for inflation). The objective of maintaining program costs at current levels is particularly challenging during periods of rapidly rising food costs and other costs, as was the case in 2008. This section provides an overview of the committee’s proposed approach and the data sources that it will consider when it estimates the anticipated economic impacts of its recommendations. Use of this approach will allow consideration of the implications of the recommended changes for school food authorities (SFAs) and commodity markets under the assumptions of full substitution and full supplementation (defined below) and the impacts at the expected levels of substitution and supplementation.

Substitution may involve either the addition or the deletion of a food outside of the school meal: (1) if a food is deleted from the school meal, the students replace it in their diet by obtaining the food elsewhere and eating it, or (2) if a food is added to the school meal, the student drops it from foods ordinarily eaten outside of the school meal.

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