USDA to Fine School Food Programs for Non-Compliance: 5 Important Things to Remember

Written by Milt Miller – Over the past few weeks I’ve listened to the fears of food service professionals concerning news of plans the USDA and FNS have for punishing non-compliant school food programs with fines. The thought of these monetary punishments have many school food professionals worrying what other bad consequences can emerge from the loins of the Healthy Hunger Free Kids Act.

“First they punish us with un-wanted cost increases based on compliance, then increased waste involving mandatory fruits and vegetables, little or no additional moneys to cover the higher cost of compliance, decreased participation due to students not accepting the new changes, loss of ala carte’ sales from the Smart Snacks in Schools guidelines, and now fines imposed for non-compliance of these financial-sustainability crushing rules. What could be more unfair?”

I remember a story of just such acts from an uncaring and uncompromising king, which resulted in some rebellious individuals (later called patriots) throwing crates of tea into the Boston harbor. While these acts over the past several years appear as unfair as the Tea Act and the Stamp Act, I wouldn’t go tossing commodities overboard to draw government attention to my displeasure with current legislation. Petitions, compromise, or the threat of open revolt tends to accomplish as much with the current administration as it did with the court of King George.

Although many feel these acts infringe on school food operator’s inalienable rights of the sustainability of program life, the liberty to offer meals that do not needlessly increase waste, and the pursuit of student acceptable products, there are five (5) key points to remember before working one’s self into a lather.

1. Most of this is not new: Schools found to be out of compliance by a certain dollar amount (greater than $6,000 in PA) for improper Free and Reduced Application calculations and/or improper recognition of reimbursable meals were required to refund a certain amount of their federal reimbursements. This has been for at least the past fifteen (15) years. I know because I know operators who had to pay them back. If this practice continued to be an issue over the next few audits, without being corrected, USDA could require 1%-5% pay back of reimbursements for that school for the year. If after several reviews the issue was still not corrected it became an egregious miss conduct and the school could lose its sponsorship in the National School Lunch Program. This is the same or similar policy mentioned this time around. If it hasn’t hurt you up to this point you will be fine.

2. If you are not sure you are compliant seek help: Pre-audit assessments are available and are inexpensive to insure peace of mind and pin-point where you need to correct areas of your program. These assessments will show where your weak areas are and will give you the information necessary to correct them before crunch time. Accurate calculations of Free and Reduced Meal eligibility, accurate reporting of meal counts, accurate reimbursable meal identification, menu compliance, and accurate production records are the key areas to worry about. Make sure you understand what is involved in all of these areas and seek training for where you believe you are weak.

3. Use the audit findings as an opportunity to improve: USDA is not actively seeking to take money back. They are asking for a demonstration of “Good Faith” efforts to comply. Don’t define your program by a low audit finding, it is a lesson and a chance to improve, not a life sentence. In most cases your state auditor will work with you and provide information on how to fix the problem (Corrective Action). These situations, most times, are painless and point you toward the training or improved processes you need so you don’t lose money. If findings exceed the dollar parameters and you have to give some money back, again it happens and it’s not a life sentence. Fix the issues, seek necessary training, and make sure it never happens again. Call us we can and will help.

4. If you are concerned you will fail an audit badly, you will, because you know you aren’t in compliance: I have had operators tell me, I made it through so now I can relax and do what I want for the next two (2) years. Compliance is an ongoing thing. If you don’t follow through you will fail because you knowingly choose not to follow the rules. You can’t look the other way for two years and expect to be compliant when you want to, you have developed a non-compliance habit, which will rear its head at precisely the worst time. Insure your staff is trained and ready at all times. A staff left to run amok will perform badly at crunch time, out of habit and fear of making a mistake. Keep training and staff development at the forefront of your operational goals. If everyone knows they are doing the right thing and compliance is the norm you will be fine. If staff know they are doing things properly they usually perform better and don’t make silly mistakes. When they are ill prepared mistakes WILL happen. Count on it.

5. Perfect Practices and Preparation Produce Perfect Performance: Use all of your available tools to insure compliance. POS reports and records, production records, free and reduced software programs, meal identification training for your staff, and finally and most important know the rules and follow them. Seek the knowledge and training necessary to optimize the use of all of your tools. There are specialists available, in all of these areas, to provide you with the knowledge and training necessary to succeed. Several times during the year audit you program for compliance. Take what you find, develop strategies to eliminate weak areas, and provide the necessary training. Sometimes a second set of fresh eyes helps to find opportunities for improvement you may take for granted. Seek help. Support is a great tool if used effectively. Set up a support system for your program for constant program growth.

The school food version of the Intolerable Acts of 2010 show no signs of going away any time soon. You are not being set-up to fail by some government ploy to take back their money. Agree or disagree as you see fit, but complying and succeeding is really your only choice for program financial stability. Know the rules and follow them and your audit experience will be a good one. Actively seek the knowledge and support to insure growth. If you don’t fear the audit you have already passed.

Milt Miller is VP of K-12 Operations at Food Service Solutions, Inc. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at

The Top 3 Training Topics for School Food Programs

Written by Milt Miller – The Final Rule on Professional Standards for School Food Professionals, has brought many needed training reforms for school food management and staff. These guidelines provide a benchmark for keeping food professionals up to date and growing in the knowledge areas necessary to perform their jobs within the new NSLP guidelines. The new guidelines mandate a prescribed number of training hours yearly for both management and staff. To comply with these guidelines the ruling provides many options for training; the three most requested programs, by our past and present clients, are Effectively Marketing Your Food Program, Purchasing and Procurement Techniques, and Understanding How to Use Production Records.


1. Effectively Marketing Your Food Program

Based on what we have seen while visiting schools, Marketing is the number one concern. School food professionals are very humble people, which is an admirable quality, but if they fail to let their student customers know what they are doing in their operations it can create a problem. Marketing a school food program is the weakest skill set we have observed. School food operators need direction in how to identify and reach their target markets in the manner they prefer to be reached. They also need to find the many free or inexpensive medias surrounding them in their schools that will effectively reach their students. Too often parents are not seen as a target market, but they make the final decision, most times, whether to buy at school or pack a lunch. We have shown many operators how to effectively reach and keep parents informed of the great things happening in their cafés.

Understanding and shaping the perceptions about your program is a critical piece of any marketing plan. Sending the proper message, by using the right medias to effectively reach students, parents, and the academic community within your school is key. Understanding and delivering menu items that meet today’s food trends and meet student needs, is also a key element of effective marketing for school food. Utilization of student focus groups, representation at parent gatherings, and keeping educators and administrators informed of program goals and offerings, are important factors in obtaining and sharing this information. The school cafés with whom we’ve worked have increased participation by as much as 15% in the first two weeks of implementing the skills illustrated and discussed in our training program.


2. How to effectively use Production Records

The second most requested topic for training is how to effectively use Production Records. This simple form has become an enigma to school food workers. The reason? An unclear understanding of the true purpose and value of this instrument. Production Records are not just a means of directing the work force or recording food usage, as is usually perceived by most café workers. This document is also a daily consolidation of necessary information for kitchen staff involving line set-up, HACCP processes and controls, meal item acceptability, cooking and holding temperature charts, portion control, and waste control. From the management side it is a great record of menu acceptability, meal identification verification, inventory control, commodity usage, per student nutrient analysis, actual cost per meal per day, and provides most of the dietary information necessary for on-site audits.

After raising the awareness of staff on the importance of this document and how simple it is to use properly, the results that usually occur are a 3-5% decrease in food cost, 10% decrease in waste, and a 10% increase in productivity. The training is about four hours, but the results in schools where we have conducted the training have been robust. Once an understanding of the purpose of this document is attained the procedures take no more than a calculator a POS items report and a pencil to complete.


3. Procurement and Ordering Techniques

The third most requested training is Procurement and Ordering Techniques. This has come to the forefront recently with the implementation of Policy 2 CFR 200, the policy on procurement for school nutrition operations. The regulations have always been there, but now the current administration, FNS, and USDA has decided it is time to enforce them and tie them to the administrative audit every three years. Though the regulations have changed very little, the enforcement piece is causing every SFA to be much more aware of them. We expect this training program to soar right to the top of the most wanted list in the next few months.

Basically all procurement is broken down to three types. Micro-Purchases, meaning less than $3,500, Informal Purchases, which is greater than $3,500 but less than $10,500 for non-perishables or greater than $10,500 but less than $150.000 For perishable items, meaning food. And last but not least, Formal Purchases, equal to or more than $150,000, which require either an IFB or RFP bidding process. Regulations and necessary forms can be obtained at, or by contacting your local state Department of Education. Every food program must have its own Food Service Account that provides a clear audit trail of all revenues and expenditures. Coupled with each type of expenditure must be a procurement explanation as to why this purchase was made and how it fits with the School Codes for Procurement. The entire process is not difficult, but it is cumbersome and can be confusing. Many of our clients are frantically seeking clarity and a condensed, more understandable version of the guidelines. Most states are conducting mass webinars to explain the new procurement processes and the audits that will follow. I would suggest attending these for the overview, then conducting small group sessions with a credible trainer for the major details. We have geared our programs to assist in gaining a better understanding of the process.

As you can readily see, the face of school food is rapidly changing and a much higher level of administrative proficiency is required than in past years. If training in these top three areas is available, it is well worth the investment to seek it. Do not be left in the wake of these new rules wondering, “What can I do now?”.

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at; 

Think Outside the Box When Marketing Your School Food Program

Written by Milt Miller – More and more school districts across the country, both managed and self-operating, are reporting declines in lunch sales due to the HHFKA guidelines. In reviewing the menus posted on these school’s websites, one quickly sees that though the guidelines have changed, their selections of entrees have changed very little (with the exception of adding beans and colored vegetables in a way their students do not understand). In replacing acceptable products with their healthier whole grain and low sodium alternatives, they have traded meeting the guidelines with serving products foreign to their customers’ taste profiles. A pizza with whole grain crust is a completely different creature than the old white flour pizza of the past. A salad made with romaine or spinach is quite different than the one made with iceberg lettuce. In trying to meet regulations, some school food operations have just substituted the new healthier replacement products for the tried and true products students understand and have eaten for years without considering the differences in taste profiles and textures.

Without investigation, the results of this change have produced less than stellar numbers in participation. In low income schools especially, operators are finding it hard to even give the food away. Waste is high and participation has declined even with students who qualify for a free or reduced meal. Most of these operators have the same reason for the drop in participation and the increase in waste: “the HHFKA guidelines”. Other reasons include: “the kids don’t like the new offerings”, “they don’t like whole grains”, “they won’t eat the fruits and vegetables being forced on them”, and the number one reason heard most, “The students don’t get as much food with the HHFKA guidelines.” My question when I read these statements is, how have other schools shown an increase in participation and decrease in waste using the same set of rules and products?

The answer to these problems as I see it? Marketing. Successful program directors educate their patrons, survey them about what they want from their food program, listen to what their student customers say, include them in shaping their program, and most importantly make their operations exciting for their customers. Think about it; children are nothing more than small adults that lack experience, but are being shaped by what they experience. How would adults react to being told what they could and could not eat and what they had to take in order to have a proper lunch? How many children see their parents eat balanced meals on a regular basis? How many families exist on convenience food high in fat and sodium in today’s two income households? To force people to act in a manner abnormal to them without answering the “why” question and showing them the benefit to doing so is setting up for failure. Educating students on the benefits of making healthy choices is key to initial acceptance. Taking this further by looking at their current eating habits and food trends aimed at their market is crucial to having a successful program. This is still America and we teach our children that they have the right to make choices. As food service professionals, we have the ability to shape those choices by providing acceptable products to our customers. If we don’t try to give our customers what they want and expect, we will lose them. Many school food programs have neglected to do this and are paying the price with large deficits.

When asked if they went out in the community and looked at what their patrons were eating outside the school, most of the operators experiencing problems now answer “no”. Most successful operators answered “yes” and said they found a way to offer these same products using healthier ingredients. Most programs have student advisory groups that give them insights into the wants of their customers. Successful programs actually listen to them and make them feel like wanted members of the program instead of outsiders. Operators who are visible, approachable, and open to their customers have a higher success rate than those who are not. Operators who take the time and effort to make school lunch exciting and students feel welcome have higher participation than those who don’t.

In most areas where I’ve had the opportunity to work with schools who sought to fix their participation issues, marketing their program was the key issue. You can’t force anyone to eat something they do not want without the use of force. Since force feeding is not an option, perhaps it is time for operators to expand their comfort zones to get out and see what their patrons want. I read the other day a school food professional said, “You can’t go by what the students say about their lunch program because they don’t give you honest answers.” This made me wonder if the answers were not honest or just not what someone wanted to hear. This was also a program experiencing a major drop in participation and thus, revenue.

To sum it all up, it’s time for school food operators to listen and think outside the box on how to deliver a product that their patrons want while staying within the HHFKA guidelines. These guidelines show no sign of going away soon so it’s time to find ways to make them work for your program. The revenues depend on it.


Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

Start Preparing for Next School Year

Written by Milt Miller – April is just around the corner! Take some time now to think about the training and enrichment needed by your staff. What are the problem areas of this school year as a whole? Are these problem areas due to a lack of training? Make a list of current issues and look at how improved training and communication can alleviate them. I used to give my staff a short quiz each year to assess the areas where we were weak as a program and would plan my training and enrichment around those weaknesses.

The implementation of the Final Rule on Professional Standards for Food Service Professionals now makes these trainings mandatory; so why not put this mandatory training to good use? Six (6) hours of training are required per year for fulltime and four (4) hours for part time staff. There are many areas required by these new rules that will help to overcome the knowledge gaps that hurt program performance. Customer service, marketing, proper use of standardized recipes and production records, cooking techniques, and proper handling of product to insure top quality are just a few areas that many programs take for granted or have skipped completely in the past. One of the most overlooked areas is meal identification and this one hurts most programs financially every year.

Take a long hard look at you staff’s needs and select programming that will help them and your operation grow. There are state programs available like the Train the Trainer Program that will teach directors and managers how to train their staff. I know, you are so busy you just can’t spare the time for training. Well how can you afford not to and now it’s mandatory! Many state departments of education have already developed curriculums for these training issues. Look into using what is available to save yourself time developing your own program. Why reinvent the wheel? “Still can’t find the time,” you say. Then why not look to an outside source like a consultant or professional trainer or chef? You can’t keep putting training on the back burner it is a requirement now. “My program is small and can’t afford the cost of a consultant or trainer,” is the most often used excuse for failing to develop one’s staff.

A properly trained and informed staff saves food operations a great deal of money and increases revenues normally lost due to lack of knowledge. Most training fees are absorbed by improved cost efficiencies and service delivery due to having a more informed and professional staff. You have to spend money on occasion to make money. Pick the areas that have hurt revenues or caused waste in the past and make them go away by improving the skills and knowledge of your staff. If your district is small, co-op with other districts in your area and host a group training session. Split the cost among the districts involved. Many times getting a professional from the outside lends credibility to the presentation. It isn’t that you don’t tell the staff the same things as the trainer, but it’s the way it’s presented and they feel important that they are getting special training. This tends to cause them to pay closer attention. It’s kind of like being a parent, your kids don’t think you know anything and an outsider knows more than you. I used to get my neighbor to tell my daughter things that I wanted her to know. She would then come home and say, “Hey Mr. Jones told me this, isn’t that a great idea?” I was just happy she got the message and accepted it. It didn’t matter to me who told her.

However you plan to train your staff doesn’t matter. What matters is that you take the time to train them. A well informed staff that understands what they are doing will save and make additional money for your food program. If they feel important and are treated as professionals, they will act professionally. Don’t let upgrading the knowledge of your staff get swept under the rug again this year. Take time to plan and present well thought out enrichment programs that will enable them do their jobs and are pertinent to what they do. I assure you the results will yield a smoother and more profitable year.

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

10 Reasons Many School Food Programs are Operating in the Red

Written by Milt Miller – School Nutrition Programs nationwide are struggling to stay in the black. Many are not succeeding, showing deficits in excess of $100K or more. The amounts of “Red Ink” spilling from school food programs since 2010 is astounding. To what can this be attributed? The new guidelines? High amounts of plate waste? Significant decreases in participation? Large amounts of unpaid lunch accounts? Increased cost of compliance? There are as many reasons, excuses, and theories as there are stars in the heavens, but it all boils down to ten main reasons why school food programs are bleeding.

In my experiences working with school nutrition programs, that are struggling to become self-sustaining, I find a combination of the following ten reasons why they are in the red.

  1. Outdated Labor Models, resulting in unmanageable salary and benefit costs.
  2. Outdated Menu Offerings, that no longer meet student customer expectations.
  3. Lack of Sound Purchasing and Procurement Procedures, resulting in excessive plate costs.
  4. Ineffective Marketing, resulting in students and parents not knowing what is being offered and what is happening in the café.
  5. Noncompliant or Nonexistent Charge Policies, resulting in high amounts of unpaid lunch accounts.
  6. Underutilization of Available Technology, resulting in poor tracking and reporting procedures, that hamper the making of informed decisions.
  7. Underdeveloped Food Handling, Customer Service, and Meal Recognition Skills, resulting in decreased participation and revenues.
  8. Ineffective Free and Reduced Meals Application Procedures, also resulting in increased unpaid lunch accounts and loss of federal and state funding.
  9. Adopting or Dropping out of a Federally Funded Program without Sufficient Research, resulting in the loss of unrecoverable revenue sources.
  10. (And this is the most significant reason) Inability to Admit there Is a Problem, resulting in continued deficits year after year.

Most of these issues go unnoticed because administrators have become desensitized. Being in their operations day in and day out they just don’t see the eminent danger to their programs, until it’s too late. Once they start to see the deficits pile up many times they are in denial and don’t want to admit they have a problem. Many times it takes a set of fresh eyes to see what is really happening. Ask yourself these questions:

  • Are our revenues steadily decreasing?
  • Is there a significant amount of unpaid lunch accounts? 
  • Are food costs above 38% of sales?
  • Are Labor Costs above 52%? 

If you have answered “Yes” to any of these questions, you have a potential unimagined problem. The next three questions can mean the difference in bleeding red or getting back on track.

  1. What is my next step? 
  2. Can I handle this myself? 
  3. Where can I get help? 

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

Start the New Year by Reaching Out to Your Students

Written by Milt Miller – Most school food programs are underachievers when it comes to student participation. The participation issue is a many faceted issue; one in which most schools blame their underachieving on the new rules and regulations. Many believe their students have lost faith in school meals due to the prescriptive nature of the new guidelines. Many say the kids don’t like being told what they must eat and don’t like the new healthy offerings.

In order to move forward we have to ponder, if the students are saying this, what are they really saying? Are we as directors and school food professionals really hearing them correctly? Or are we hearing something entirely different and easier for us to swallow? Are we really listening? Most times the difference between mediocre participation and great participation is found to be in the translation of what we really hear our customers saying.

I just finished reading an article about the 2015 School Nutrition Association of Pennsylvania Director of the year Jillian Meloy. Jillian is the Food Service Director at Greater Latrobe School District in PA. This woman is really hearing what her students are saying and she is responding. When I read this article I knew what my next article would report. Great participation is directly proportional to the effort taken to listen and understand what customers are truly saying, and responding to those requests. 

“Your clients are the kids,” Meloy said. “They really have a voice in what they want to eat, what they like, what they don’t like.” “It’s really showing them what a balanced meal is. If the students take every single component, it’s a pretty meal, and it’s very, very balanced.” Jillian keeps track of what fast-food and chain restaurants are serving as a way to see what foods are being marketed to students and what they want to eat. She uses that information to develop meals that are appealing while being healthy. “I watch what they’re eating. I see what they’re putting in their grocery carts at Wal-Mart. That type of stuff helps me see what the kids really like to eat,” Meloy said.

What do her peers say about her? “She just doesn’t stay stagnant. She’s out there reaching out to the families of her district and different community groups.” Meloy works with a group of students to get feedback on what meals are popular and what should be changed. She also organizes samples of new menu items to get feedback on whether they should be added to the menu. That feedback will continue to be important as more regulations are passed on to school districts. Meloy said, “The next challenge is reducing levels of sodium in meals while still making them appealing.” As Jillian continues to adapt meals and encourage healthy eating habits among students, she hopes that her efforts impact what foods they eat throughout their lives. “You’re really making a difference, because they’re still growing,” she said.

Wow, congratulations Jillian on a job well done! How many of us are really listening to what our student customers are saying? How many of us take the time to look at what they are eating outside the school café”? This is a new year and at this time of year we are starting to look at next school year and plan our approach to winding down the old year. Why not take this as an opportunity to make a commitment to reaching out to our student clients and truly listening and looking at what they are really telling us?

How many of us are developing menu items based on current trends, not just using new products to produce the same old tired menu items? How many are effectively using student focus groups and not just going through the motions to say we have one? How many are reaching out to parents and community organizations to share what we are doing in our café’s? Are we providing our staffs the opportunity to tell us what students are really saying?

As this New Year dawns, let’s take the opportunity to make the remainder of this year and all of next, all about reaching out to our customers and meeting their needs. I guarantee your participation will increase and so will your revenues. If you are having trouble thinking of ways to do this, contact me. I promise I will listen and share some ideas based on what you are telling me. Let’s make this year the year of the customer!

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

You know your school food program is successful if…

Written by Milt Miller – Today in the school food arena, with all of its new rules, programs, and political views, there are virtually a million ways to show a program is successful. None of them define success as being self-sustainable financially, but a fiscally self-sustained program is deemed successful none the less. The whole successful program identification trend kind of reminds me of the old Jeff Foxworthy comedy routine, “You know you are a Redneck if…” At this holiday season, I would like to share my list of ways one can decipher if their food program is in fact a success.

You know your school food program is successful if: 

1. You have implemented all of the meal pattern requirements mandated by the Healthy Hunger Free Kids Act.

2. You have implemented the Smart Snacks in Schools regulations.

3. You have appropriately raised paid lunch prices as mandated by the Equity in School Lunch Act.

4. You do not deny any child a meal due to an exceptionally high unpaid lunch account.

5. You have implemented the Community Eligibility Provision allowing every child a free breakfast or lunch daily.

6. You have instituted a Weekend Back Pack program to insure low income children are receiving meals on days school is not in session.

7. You are currently planning and scheduling staff development and enrichment programs in compliance with the new Professional Standards for School Food Professionals policy.

8. You have instituted a Farm to School or Buy Local purchasing practice at least two days a week.

9. You have become a Summer Food Program sponsor.

10. Your meal participation exceeds the national average of 65%, even though it takes at least 82% to be fiscally sound.

11. You provide nutrition education in the classroom.

If you can answer yes to at least one or more of the above listed items, in the eyes of the White House, FRAC, FNS, and USDA your program is successful. The unfortunate part of this success is that many of you, after accomplishing these lofty feats cannot meet your fiscal responsibilities without help from your district’s General Fund. Nowhere in this formula for success is there a requirement that a program must be financially self-sustainable as most school food programs are supposed to be. Some of you are fortunate to be fiscally sound, but most are not. Some have left the NSLP and foregone reimbursement to serve their customers what they want and have willingly shouldered the extra financial burden. This to me is a noble act of true customer service. These programs have decided to shoulder a small loss of income to serve their students and insure they all receive the foods they want, than to shoulder a greater loss due to increased waste and decreased participation. In some cases leaving the NSLP was the right move and resulted in no loss at all or a small acceptable loss.

I am not saying that these lofty aforementioned success indicators are wrong and not needed. I wholeheartedly support them and believe they are much needed, but with some changes to insure financial sustainability and increased flexibility. In these times more and more school boards and administrators are looking at privatizing their food programs. Alas, even food management companies, with their food service and business expertise and enhanced purchasing power are struggling to keep the programs they manage in the black. These are the times of over regulated, underfunded, cost prohibitive, over politicized, and ever changing government school meal policies. Legislators need to understand that non-profit does not mean to lose money. Some of the largest and most successful non-profits make money or they would not be able to continue service at an acceptable level. Their growth and outreach would be catastrophically inhibited.

I am a proponent of quality, compliant, and financially sound school food programs. I view this industry as a much needed service to today’s students. To all of the dedicated school food professionals in this country, it is my fervent wish that during this holiday season our government leaders work diligently to enact revisions to current policies that provide adequate funding, increased flexibility, improved regulation, and financial stability to this great industry. Happy Holidays and a very prosperous New Year to all.

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

How to Control Unpaid Lunch Accounts

Written by Milt Miller – Unpaid school lunch accounts appear to be becoming the new school food crisis. Of late, everywhere I turn I see articles about the severity of unpaid lunch accounts in schools. How has this happened, and why was it allowed to happen, and what can we do about it, appear to be the major questions asked by school administrators and board of education members nationwide. The answers to these questions are; there have always been unpaid lunch accounts, they have been allowed to grow due to a reactive rather than a proactive approach to controlling them, and through a lack of clear charge policies. They can be controlled by developing clear charge policies and using the appropriate technology to be proactive in handling them.

Most schools make the same mistakes on controlling unpaid lunch accounts nationwide. They have no clearly communicated, state approved, realistic charge policies in place from the start. They have no standard operating procedures in place to proactively ensure that lunch accounts are kept up to date, as much as possible. They also fail to realize that there will always be some unpaid lunch accounts unless a hard line approach is adopted, and even then there will always be some bad debt. Here are some basics for controlling unpaid lunch accounts.

As more and more families become eligible for Free and Reduced Meals better recordkeeping is necessary. The largest creator of unpaid lunch accounts is the time between the expiration of last year’s benefits and the submission and approval of this year’s Free and Reduced Meal Application. The thirty (30) day overlap period from last school year’s entitlements and this year’s application submission is key to controlling unpaid accounts. With today’s technology when last year’s benefits expire and no application is submitted the student is immediately moved to the paid category and the meter starts running up unpaid lunch bills. Sending a notice that the child owes money will get you an application submitted but you will never see the money for the interim period! Be proactive run reports on expiring applications and contact parents before their entitlements run out. Run these report weekly from the end of the first week of classes until the thirtieth day of school and keep contacting parents to inform them they are about to lose their meal benefits. Involve your building principal, after all it effects their Title 1 moneys.

Set clear, state and board approved charge policies that follow the national guidelines for charged meals. This policy is hard for schools to find, being called “The Lost, Stolen, or Misused Ticket Policy”, with ticket meaning any form in which a school meal is paid for. Its actual name is, “FNS Instruction 765-7 to Section 245.8 of the National School Lunch Act.” This policy can keep schools from setting charge limits too high making it harder to collect larger unpaid accounts. It also provides you with a hard fast set of reference points to show to your board and administrators. If this policy is followed state approval is a definite. Once this policy is adopted it must be clearly communicated to all parents, students and employees. It also should be posted in all public areas of all schools and in a prominent place in each café’. All employees should be trained how to appropriately enforce this policy. Too many times school administrators end up on the wrong end of bad press, due to a lack of clear communication of the school charge policy and the lack of clear concise training on how to enforce it.

The proper handling of the two above mentioned keys to controlling unpaid lunch accounts will greatly decrease them in a relatively short time and provide a proactive rather than a reactive approach to controlling them. Give them a try and you will be pleased with the results.

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

5 Emerging School Food Trends

Written by Milt Miller – Trends emerging in school food today get their origins from America’s health and nutrition conscious restaurants. Eateries, large and small local shops, and corporate chains that focus on healthy and fresh as well as kid friendly American and ethnic cuisines. The American Dairy Association (ADA), Farm to School Programs, and other champions of fresh fruits, vegetables, and dairy, lend support to these popular new kid favorites. These emerging trends all involve several common themes that make them school food compliant and kid friendly. They all involve fresh ingredients, are or can be hand held, are customizable, provide choices, fast, and are colorful and produced in front of the customer. Made-to-order, fresh, gluten-free, nut-free, Grab n’ Go, whole grain, and healthy are the buzz words of America’s dining preferences.

Many of these new cuisines involve special equipment and special training to insure their success on a large scale, but with some thought and minor limitations of choice, these trends can breathe life into a stagnating breakfast or lunch program. Too often directors and their staffs jump into providing a popular trend item with little or no thought to how the product is best delivered in their operation. Limitations on equipment and basic skills needed are ignored to keep up with the emerging student desire for new trendy items.

A classic example of this is the increasing popularity of fruit and vegetable smoothies. These great tasting beverages meet several components of a reimbursable breakfast or lunch. They are nutritious, hand held, provide choices, made-to-order, gluten free, nut free, but “fast” gets lost in the shuffle and participation plummets. The ADA has provided funding for equipment (blenders), cups, recipes, and on-site support to make this great product available in school cafes. All participants in this process that I have spoken with, from staff to student customers, have shared that supply is many times overshadowed by demand and the speed of service goes out the window. The blenders specified and provided by ADA, at my last investigation make smoothies ten (10) at a time (1 Gallon). Great for a slow day, but with 400 students or more in a sitting this can be a real time and delivery drag. These are great for a specialty bar and an area with small participation, but for a high volume area this can be a disaster, creating frustration for both staff and students. Not to mention speed of service becomes non-existent.

My suggestion to making this trendy item a hit involves the spending of between $300 and $800. An immersion blender (Burr Mixer), allows staff to make smoothies in large quantities. By large I mean five (5) gallons or more at a time. Making two (2) or three (3) types of the most popular smoothies, pre-pouring them and making them part of a Grab n’ Go breakfast or lunch can make lines of service move much faster. Blenders can be set-up at a smoothie bar in another area, providing customizable choices and showing the made to order concept for those who don’t mind waiting. This system makes production and service easier for the staff and faster and more convenient for student customers. The immersion blender will pay for itself in a matter of weeks and can be used to make other concoctions for other fresh items. I have tried this with great results in several client operations.

Many of these trends don’t always work in school settings like they do in restaurants where people expect to wait a bit to be served. Many involve the major expense of a remodel or purchasing a major piece of equipment. A bit of thought and some minor changes to the concept can and will work well in most schools without a major cash outlay in the beginning.

Below I have listed several of the new hot trends coming to school food. Along with these items is a list of equipment and design considerations. Most call for major renovations and equipment purchases that many schools can’t afford or don’t have room for. With some creative thinking and some minor limitations any of the following can be made to work in most school cafes:

Fruit and vegetable smoothies

  • Equipment considerations: High-powered, noise-reducing blenders and extra green-colored chopping boards for prep work.
  • Design considerations: More countertop space for placing blenders on the serving line to make the action associated with making smoothies visual to the students; under-counter or added refrigeration can keep fresh fruits and veggies within reach of staff during busy periods; locate this task near a sink or water line for quick and easy cleaning between smoothie-making.

Authentic Mexican food 

  • Equipment considerations: High-powered blenders for made-from-scratch salsas; stock pots or combi ovens for braising proteins such as carnitas and barbacoa; flat-tops that staff can use to make quesadillas, tacos and burritos to order; tortilla presses and warmers.
  • Design considerations: Flexible equipment and workspaces that can accommodate Mexican and other foods; refrigerated sandwich prep tables for holding different ingredients that can allow students to build their own Mexican-inspired meal one day and sandwiches or build-your-own pizza the next.

Made-from-scratch pizza

  • Equipment considerations: High-powered gas ovens with aesthetic appeal or conveyor ovens in open view; pizza peels and dough presses.
  • Design: Refrigerated sandwich prep tables with different toppings for students to build their own pizza with the meats, cheeses and veggies they want.

Salads and Fruit

  • Equipment considerations: Extra cooler space and prep tables.
  • Design considerations: Expanded, build-your-own salad bars with fresh fruit options, proteins like hard-boiled eggs, chickpeas and tofu, and pre-made salads and other vegetable-forward dishes for faster grab-n-go and for younger children that might struggle with building their own meals.

Hand-Held Foods

  • Equipment considerations: Refrigerated grab-n-go display cases for pre-made sandwiches and wraps; hot-holding units for pizza slices, empanadas, breakfast sandwiches, tacos and other pre-made, hand-held items made just before the lunch rush.
  • Design considerations: Expanded grab-n-go, retail-like space and displays positioned so that students can bypass the main line.

These ideas can increase participation and add excitement to your school café. With a bit of creative thinking they are very doable in school settings. Consider the idea I have given you and if it works try another. If you need a bit of coaching, just let me know I would be happy to discuss implementation with you.

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;

Surveys show support for healthy school meals and staff training


Written by Milt Miller – I just finished reading an article published on Agri-Pulse, August 18, 2015, regarding two recent surveys commissioned, one by the W.K. Kellogg Foundation and the other by the Pew Charitable Trust and the Robert Wood Johnson Foundation, concerning school food programs. For those who have not seen it a para-phrased version is included below.

The article speaks to how higher nutrition standards for school meals imposed by the Obama administration retain strong public support, according to a new poll. The poll shows that 57% of Americans think school meals have gotten better.

However, a second survey released Tuesday suggests many public school nutrition directors have been struggling to get their staff trained to carry out the standards, which were implemented under direction of the Healthy, Hunger-Free Kids Act (HHFKA).

A poll commissioned by the W.K. Kellogg Foundation, conducted in May and released August 11, 2015, found that 48 percent of the 1,200 randomly selected adults surveyed thought the new healthy meal standards should be strengthened. Thirty-eight percent said they should be kept the same while seven percent said they should be lowered.

When asked to rank the contributors to childhood obesity, respondents placed blame on less recess time and fewer physical education programs in school over other contributors, including school dining programs or urban food deserts.

Now, four years since the nutrition legislation was enacted, fifty-seven percent of those polled stated that cafeteria food has improved, twenty percent say it has stayed the same, and nine percent say it has declined. Over this four year period public opinion of school food appears to have improved by thirty-one percent, up from twenty-six percent in April 2010.

One of the most significant findings of this survey was that only thirty-seven percent of food directors have budgets for the staff development and training they say is crucial to meeting the new standards mandated by the USDA. Seventy-two percent of the directors polled said support from state agencies was not sufficient to improve this area.

Training needs requested by the 3,372 directors polled were quite diverse. Sixty-nine percent requested training or additional reimbursement for completing paperwork on the evaluations that assess compliance with the National School Lunch Program, more than sixty percent required guidance on menu development, marketing and promoting new menus, sixty-three percent indicated more training is needed to increase understanding of compliance with new meal and nutrient requirements, twenty-eight percent required additional training on purchasing and operating new equipment, and twenty-three and thirty-six percent respectively, needed guidance in employing basic cooking and nutrition skills safely. To fix this issue, Pew and the Johnson Foundation recommended schools and all levels of government prioritize funding for training. This position was backed by almost half of those surveyed in the Kellogg poll.

After reading this article I understand that these surveys lend credibility to the reasons behind the new Professional Standards for Food Service Professionals Training Guidelines. Anyone in the industry knows that training has been the most needed ingredient for the implementation of the HHFKA guidelines in schools. We also knew that as close to breakeven as most programs always seem to be, that very little if any funds would be budgeted for training in cooking basics and marketing. These are the areas that traditionally have taken a back seat in the training process and now, with today’s students they have become the most needed.

Students of today are savvy shoppers with discerning tastes. They know what they want and what they are willing to pay for. They know restaurant fare and care little for home-cooked goodness, as most meals they get are not from home. They know presentation, freshness, good customer service, and perceived value. All areas where most school food programs miss the mark. That seems to be the ingredients needed for a successful front of the house.

The back of the house needs basic cooking and food handling techniques, proper setup to support flow of service, basic food processing techniques to control waste, and meal identification skills. These areas will create a strong back of house and insure significant increases in participation. Without instilling a concrete grasp of the aforementioned basics, no program can expect to succeed. Let’s look at the facts of life and sports… great basics lead to success and championships. In all walks of life the person or team with the most complete grasps of the basics is destined for success.

On Capitol Hill, the nutritional value of school lunches under the new standards is not in question as much as the operational costs they say comes with them. Opponents of the USDA-set standards say they lead to hikes in food waste and declines in cafeteria revenues, because students won’t eat the healthier foods.

SNA (School Nutrition Association) spokesperson Diane Pratt-Heavner said, “The Pew survey highlights the need for increased funding for schools working to meet new standards.” “The overwhelming complexity of the nutrition standards… is cited as the top training need for frontline cafeteria staff” by SNA membership, Pratt-Heavner told Agri-Pulse. “As schools struggle to manage the higher cost of meeting new nutrition standards, they (will) need additional resources to cover training costs.”

Katie Wilson, the deputy undersecretary for food, nutrition and consumer services, wrote on the USDA blog Monday that the department was “prioritizing thorough, ongoing trainings” for school kitchen staff through its Team Up for School Nutrition Success initiative launched last year. The program provides schools with financial management, youth engagement and menu planning training, in addition to guidance on food safety, professional standards and utilizing local produce. “USDA understands that by training leaders locally, we can expand our reach tremendously and by empowering mentors at the state and local level, we provide communities with lasting, personalized support that is there to stay,” Wilson said.

All three above mentioned camps show diverse views to solve the problem. In my opinion, all sound like better training for directors and managers and the need for more funding from SNA. USDA’s training programs for the new standards do include getting back to basic criteria. These I hope will not be overshadowed by the politically correct choices on menu planning, procurement, and nutritional standards, which smack of training for directors, not staff. More funding is needed, but Congress is looking to control waste instead of opening purse strings. A great director or manager knows the fastest way to a championship is having a strong, basically sound staff. The revenues generated and found by having a well-trained staff can carry a program.

This year when you are looking at training programs that will gain you the sufficient number of CEU’s to comply with the guidelines remember these simple steps: 

1. What are my staff’s greatest weaknesses and strengths?
2. What programming will best improve those weaknesses?
3. What programs will most improve areas of lost revenue and declining participation?
4. Where will I get the most bang for my buck?
5. Is the presenter speaking and presenting on a level best understood by my staff?
6. Are the contents of the program suited to my immediate needs?
7. Is this program getting me back to the grass roots and back to ground level basics?

I guess what I am trying to say is, all canned programs are not created equal. A program customized to your specific needs, while more expensive (maybe) may yield better results in the end. Review all programming that your staff will receive to make sure it is appropriate. Interview presenters and know where they are going with what they are presenting and insure it meets your needs. Some free programming is not what you want just because it is free, make sure it is at an appropriate level and meets your needs. Finally, insure that training dollars are being wisely spent. Training that produces minimal results is virtually worthless. All training programs are not created equal.

Politically correct training programs, ones that only address the hot-button issues of today, produce politically correct CEUs. They produce little else and if you don’t have the basics to back them up, you have an empty certificate of accomplishment. Time management, HACCP, Servsafe, and menu planning are great for directors and some staff, but if you don’t have the basic food handling and cooking knowledge to back them up; what are you really getting? Do I have training programs? Yes. Are they the right ones for your program? You tell me. I’m not advertising and saying mine are better. Maybe for some they are and for some they are not. But let’s discuss mine or anyone else’s and see. If mine are missing the mark, I would rather learn from you than waste your time and money.

I love this industry and want to see the best possible results to insure our students are getting the best possible service and the operations are increasing participation and revenues. I want every school food operation to be as successful as it possibly can be. All I am saying is training is mandatory now, so choose wisely!

Milt Miller is the Principal and Chief Innovator at Milton Miller Consulting. Throughout his 32 years in the food service industry he has managed, operated and assisted food service programs to become successful. For more information on this and other topics, contact Milt at;