Year of Publication
Martin School of Public Policy and Administration
This report is intended to evaluate the implementation of Senate Bill (SB) 172 in Kentucky's public schools. This law requires that all schools in Kentucky implement strict nutrition standards that apply to all foods sold during the school day. This report highlights the different methods used by selected schools in implementing the requirements in SB 172. In performing my analysis, I traveled to different schools in central and southeastern Kentucky to assess how these select schools were meeting the requirements of the law. Site visits allowed me to discuss implementation strategies with school administrators and aided in my understanding of how the regulations were implemented at the street level. I also interviewed district food service directors to discover how they feel the requirements of the law should be implemented in the schools. I then went to the very top level in the state of Kentucky, and asked state administrators in the Obesity Prevention Department and the State Board of Education select questions about this policy. This was all part of an analysis of communications that demonstrates how information provided by state officials has traveled down to the schools. The analysis identified communication errors between the state and the schools. These communication errors would most likely manifest in some deviation from SB 172ís requirements or a school failing to meet compliance with said regulations.
I initially selected 24 schools to contact from these two areas of Kentucky. Twelve agreed to participate. I selected these schools for contact for the following reasons: these schools were in a geographic location that made them easily accessible to me, I had time available to gather data from schools and administrators, and I examined a heterogeneous mixture of multiple school districts, rather than a single school system. These criteria were intended to increase the different methods of implementation studied for the purposes of this report. I intended to maximize the schools and school districts in my study given the short time frame allowed to create this analysis. Certain factors kept me from obtaining all 24 schools for my report: administrator refusal, scheduling conflicts, state academic testing conflicting with the allotted window of time for data collection, and the short time available to collect data. These factors all influenced the number of schools I was able to visit for my report. The state testing period (called the CATS test) is held in Kentucky public schools every spring of the year, the exact time that I was performing my data collection in the schools. This was one of the most used excuses for administrators being unable to meet with me. The school administrators that refused for this reason told me they had many district meetings and meetings with other school administrators to organize for these tests. Although this may not be true of all administrators' refusal to participate or not respond to my numerous attempts to contact them, I do believe that it may explain a majority of the non-participation. However, I feel that this has had no affect on the results of my study.
Through my study, I found that, for the most part, every school is using a different method to comply with the regulations in SB 172. There are also no accountability measures in place to ensure that the schools are complying with the requirements of the law. The requirements in SB 172 have not been clearly communicated to school administrators and food service directors. There is a level of ambiguity in their understanding of what regulations apply to certain schools. This problem stems from the process of the bill's creation, where draft versions were made available to school administrators, but the final requirements were not clearly articulated from state personnel to the schools. The financial burden of this law falls squarely on the shoulders of the schools; most schools studied lost significant discretionary funds from the changes required to their vending sales and contracts. This loss of funding affected operations in some schools. The state however, provides ideas for alternative fund raising so that schools can potentially offset any losses suffered in the schools. Lastly, SB 172 contains an exemption for foods that meet the requirements of the National School Lunch/Breakfast Program to be sold in school meals and a la carte sales. Comparatively speaking, the requirements of the National School Lunch/Breakfast Program are less stringent than those of SB 172. This exemption potentially allows foods that would be banned from sale in schools under SB 172 to be offered via the a la carte offerings, defeating the purpose of the law.
This report makes recommendations to further improve the implementation of SB 172. The state should make an implementation model available to the school food service directors and school administrators that demonstrates an easy way to meet the law's requirements. Successful schools and their methods of implementation should be benchmarked by the state and information about them made available to all schools in Kentucky. The state should create a governing board to assess schools' compliance with the regulations in the law. It should also communicate or create financial penalties and/or incentives to entice schools to comply with these regulations. The state also needs to clearly communicate the requirements of this law with schools through this governing board. This will remove any implementation inconsistencies that still exist in Kentucky's schools. Lastly, the requirements established in SB 172 should be reworked so that a la carte items are no longer exempt from the regulations of the law provided they meet the requirements in the National School Lunch/Breakfast Program; the nutrition environment should be consistently enforced in all Kentucky public schools.
Brumbach, Bill, "Senate Bill (SB) 172: Governance of Nutrition in Kentucky Public Schools: Implementation Analysis Final Report" (2007). MPA/MPP/MPFM Capstone Projects. 165.