Do US preschools ban lunches being brought to school?

Question

In October 2013, on My 2 Crazy Curls, a blogger from Richmond, VA, reported receiving a letter from her child's preschool, explicitly banning students from bringing their own food to school without a medical reason.

Dear Parents,

I have received word from Federal Programs Preschool pertaining to lunches from home. Parents are to be informed that students can only bring lunches from home if there is a medical condition meriting a specific diet, along with a physicians note to that regard.

I am sorry for any inconvenience. If you have any questions concerning this matter, please contact [name redacted], the Health Coordinator for Federal Programs Preschool at [number redacted].

By itself, this claim (that the preschool sent such a letter) is barely notable, but it has been adopted as a rallying point by a number of anti-GMO web-sites.

Examples: 1, 2, 3, 4, 5, 6

Is it, as claimed, policy in Federal Programs Preschools, that students are not permitted to bring their own lunch to school? (Bonus points: What is a Federal Programs Preschool? For example, do all preschools operating in the US fall under this term, or are there US preschools that are not Federal Programs Preschools? If the second, how does one determine if a specific preschool is Federal Programs or not?)

Answer 1

"Federal Programs Preschool" appears to refer to the Health and Human Services Head Start program.

I can confirm this is policy is in place for at least some preschools.

Here's an example of a policy at one Head Start preschool that forbids outside lunch:

All children in Head Start are served breakfast and lunch, and a snack in the extended day programs. We provide one-third to one-half of the child's daily nutritional need. All meals are USDA approved. Meals must be consumed during mealtime only. Food items high in nutrients and low in fat, sugar, and salt are offered to the children. Also, outside foods are not allowed. This includes goodie bags filled with food items during the holidays and birthdays.

^{Highlights in original.}

---

My wife works for a subsidized preschool program, and she has provided me with some (anecdotal) confirmation of the policy and shared some of her expertise in the background for the policy.

Her preschool does not allow outside meals unless there is a medical reason (with a doctor's note).

She said this is the norm for subsidized preschools in this area. This policy applies even to their non-subsidized "full fee" children. Private schools tend to be more flexible.

There are a number of reasons for this policy at her school:

• One is because they are a publicly subsidized program with mainly low-income families and they want to ensure that the children are receiving healthy meals that meet recognized federal nutritional guidelines. Parent supplied meals are often lacking in nutritional balance. (For example, in one field trip where parents did supply meals, one child's "meal" was 3 different bags of chips.)

• Another reason is due to allergies. They have a protocol that they have to follow to prevent children from coming into contact with foods that they have an allergy to, and it's much harder to do this with meals brought from home as they have no way to verify ingredient lists or keep track of every child's meals.

• Another is storage and preparation. They have little staff time or space to devote to meal storage and preparation, and keeping track of dozens of home-brought meals would cut into the time available for meal prep.

• Finally, there are liability concerns. They have no way to assure the food safety for a home-brought meal, as they don't know how it was prepared or stored prior to arrival. Yet a parent may put blame on the school for improper storage if a meal is spoiled and sickens their child.

This all sounds like a bunch of needless complexity and rules for something as simple as a home-packed bag lunch, but they are an understaffed non-profit on a razor-thin budget, subject to both city and state scrutiny for licensing (and funding). They also have the scrutiny of parents that have a propensity to put blame on the agency for the most trivial of concerns -- which leads to a licensing investigation that takes away valuable staff time.

Since private schools usually have more flexible meals policies (because they have additional staffing and funds), parents that don't agree with the food policy can find a more acceptable solution at a private agency. However, this is a much more costly solution for those that qualify for subsidized child-care.

Answer 2

Out of curiosity, I contacted Catherine Digilio Grimes, Director, Office of School Nutrition Programs, Virginia Department of Education and Michael Welch, Director, Division of WIC & Community Nutrition Services, Virginia Department of Health. Director Welch also inquired with his USDA contact. They said there are no federal or state (that is VA) policies, guidelines or regulations that would prevent a lunch from home. This specific preschool center "may have decided to restrict lunches from home because they can’t get reimbursed".

---

From: Digilio Grimes, Catherine (DOE) Oct 23

Mr. Weber, I am not aware of that any school restricts children from bring their own lunches.
Do you know what school and school division this is?

Catherine

Catherine Digilio Grimes
Catherine Digilio Grimes, MS, RD., LDN, SNS
Director, Office of School Nutrition Programs
Division of Finance and Operations
Virginia Department of Education
101 N. 14th Street
Richmond, VA 23219
Office Phone (804) 225-2074
Fax Number (804)786-3117
[email protected]

---

From: Digilio Grimes, Catherine (DOE) Oct 23

Eric,
I am going to forward your request to the Virginia Department of Health. Michael Welch who is the Director who oversees the USDA Child Care programs. He may have more insight into this preschool.

Catherine

---

From: Digilio Grimes, Catherine (DOE) Oct 23

Mike,
I received this email for Mr. Eric Weber as concerned citizen related to the blog in the link below that show a note and comments saying children are not allowed to bring in their own lunch . We believe it s a day care program in Richmond area. Not sure if they are part of CACFP or not. Would you please looked into this and get back to Mr. Weber

Thanks

---

From: Welch, Michael (VDH)

Mr. Weber,
I have received your email from Ms. Digilio Grimes. I have sent to my contacts at USDA to determine if any such regulations exist for day care or preschools. As soon as I hear back, I will let you know.
Thanks

---

From: Welch, Michael (VDH) Oct 23

Mr. Weber

From my USDA contact:
There is no federal policy that restricts parents from supplying meals from home. The center may have decided to restrict lunches from home because they can’t get reimbursed but there is no such federal policy.

Answer 3

Federal Programs Preschool is actually just the (uninspired and confusing) name of a set of Head Start facilities.

From the Parent Handbook of one facility in Henrico, Virginia:

Federal Programs Preschool provides a high quality, active learning environment for at-risk four-year-old children in twenty-three (23) locations.

You can prove this letter was sent by this facility by matching the name of the person in the note to the name of the Health Coordinator at the school.

There isn't specific wording on the school's regulations that states it is against facility policies for a parent to pack their kids' lunches, but it does mention guidelines for shared foods like birthday cupcakes:

Due to Federal Regulations and Safety Guidelines, all prepared foods brought into the classroom (i.e., birthday cakes, cupcakes, cookies, etc.) must be store bought or restaurant prepared.

Also, there is a vague rule that seems to imply that parents have to apply to get the lunches for free or at reduced prices:

For Breakfast, lunch and snack are provided at each location, at no cost to participants. Free and reduced lunch applications must be completed by all participating families. This is a program requirement.

None of the facility policies cite a single federal regulation or law.

Now, as for the Head Start federal regulation, according to the official federal law and guidelines approved by the U.S. Department of Health and Human Services, there is no specific regulation I could find stating that parents could not provide home lunches for their children, nor any regulation that would imply this. It appears to be the total opposite, in fact, as stated in the regulation, part 1304.23 Child Nutrition, section b paragraph vii subsection 4 (top right of page 128)

parents and appropriate commu­nity agencies must be involved in plan­ning, implementing, and evaluating the agencies’ nutritional services.

I think it's very safe to say this is a (misinterpreted) rule of the facility and staff of this Head Start preschool, rather than a broad requirement/law by the federal government as many of these blogs are implying.