reasons, including the belief that they would not have their applications accepted due to a lack of funds and due to the USDA "freeze" on program expansion?

Question No. 3: If the reimbursement rates for the breakfast program were substantially increased, e.g., 30 cents for every meal served; if the labor and supervision expenses of the program were reimbursed; if substantially increased nonfood assistance funds were available to provide equipment to schools without such equipment; and, if you and your office fully advertised the program and encouraged schools to apply for it: How many schools do you estimate would apply to implement the breakfast program?

We also invited the State officials to make whatever additional comments they deemed appropriate.

The first question in our survey merely reflected the question asked of the States by USDA. The figures provided as answers to the second question, when added to figures provided as answers to the first question, reflect the true desire for program implementation. These were, I must stress, under the present, wholly inadequate reimbursement structure of the program. Comment after comment from the State directors told us that the current reimbursement structure is far too meager and that the only meaningful way of determining the number of schools really "desiring" program implementation is to make that estimate in the context of an adequate funding structure. The statements of the State directors are contained in the signed answer sheets which I have here. We have most of the answer sheets here and we will submit those to the committee. Documentation of the need for a higher reimbursement structure will be provided by Mr. Irvings in subsequent testimony.

Senator HART. At the appropriate point in the record,* if there is no objection, we will include the State directors' replies that you have just mentioned.

Mr. POLLACK. Thank you, Senator Hart.

Consequently, the answers to question No. 3 reflect the true number of schools "desiring" program implementation. The answers to questions 1 and 2 merely reflect the number of schools desiring the program under a wholly inadequate funding structure.

The results of our survey, in comparison to the Department's report, are astounding. Given the present, inadequate funding structure, the State directors have told us that the true desire for program implementation is 430 percent higher than the figure reported by USDA. Instead of there being 1,141 schools in the country-excluding Guam and American Samoa-that want to implement the program-as reported by USDA-there are at least 4.903 schools desiring program implementation at the present, inadequate reimbursement levels.

Even more significant were the estimates of the schools desiring program implementation under an adequate reimbursement structure. The State School Food Service Directors estimated that there are 21,720 schools in the country that want to implement the breakfast

*See Appendix 1, p. 58.

program-more than 19 times the nationwide figure provided to Congress in the Department's report.

It is interesting to note that Minnesota's projected need-1,840 schools is more than 1.5 times the size of USDA's figures for the entire country-1,141 schools. The estimate for Massachusetts-1,636 schools-is almost 1.5 times the nationwide total, as is California's estimate of 1,600 schools; and New York's total of 1,530 schools. The desire for program implementation in Texas, 1,250 schools, is also higher than the figure ascribed by USDA for the entire country.

COMPARISON OF SURVEYS

The following then, is a State-by-State comparison of USDA's figures and the actual figures as reported to us by the State directors. If you will look at the chart that we have set up over here, this chart indicates-reading from your left and down and then up again— this chart indicates how many schools in each State desire to implement the breakfast program. In column 1 we have indicated the number of schools that the Department of Agriculture ascribes would like to implement the program. In column 2 and column 3 we set forth the figures as provided to us by the State directors in their signed statements. Column 2 indicates how many schools would desire the program, given the present inadequate funding structure; and column 3 indicates their estimate of the number of schools desiring the program under an adequate funding structure.

Look at Alabama, as an example. The Department of Agriculture has indicated that there are no schools in Alabama that would like to implement the School Breakfast Program. The State Director of School Food Service in Alabama indicates that-even under the present, inadequate funding structure-there are 189 schools that would like to implement the program. The State director also estimates that there are 800 schools in the State that would like to implement the program if a proper and decent funding structure were made available.

Arizona: the Department's report of 9 schools desiring the program is accurate as far as the inadequate funding structure is concerned. However, if an adequate funding structure were provided, then the State director estimates that there would be 500 schools that would want to implement the program.

In California, the Department of Agriculture has estimated that there are 22 schools in California that would like to implement the program. Given the present, inadequate funding structure, the State director estimates that there are 377 schools in that State that wish to implement the program. If an adequate funding structure were developed, there would be approximately 1,600 schools that would implement it.

To go on-in Florida, the Department of Agriculture estimates that there are no schools that would like to implement the program. The State director indicated that with or without an adequate funding structure, there are 725 schools that would like to implement the program.

There is a disparity with Illinois as well. The Department ascribes 26 schools to the State of Illinois as wanting the program and yet the

State director ascribes 500 schools, even given the present, inadequate funding structure.

In the State of Iowa, the Department estimates that there are no schools that would like to implement the program, but the State director informs us that with an adequate reimbursement structure there are approximately 1,000 schools that would like to implement the program.

I would refer Senator Hart to the State of Michigan, where the Department estimates that there are no schools that would like to implement the program. The State director has indicated to us that given the inadequate funding structure there are 180 schools that would like to implement the program, and with a decent reimbursement structure there are 480 schools in that State that would like to implement the program.

Senator Bellmon, in the State of Oklahoma, the Department has estimated that there are 17 schools that wish to implement the program. The State director informed us that given the present, inadequate funding structure, there are 42 schools that would like to implement the program; and, with an adequate funding structure there are approximately 200 schools that would like to implement the program.

In State after State the figures are far different than what the Department has reported to the Congress. Pennsylvania, the Department reports 132. The State informs us that there are 800. In the State of New York, the Department informs us that there are 32. The State director informs us that--even given the inadequate funding structure-there are 530 schools that would like to implement the program; and, given a decent funding structure, another 1,000 would like to implement the program. In the State of Texas, the Department estimates that there are 202 schools that wish to implement the program; and given the inadequate funding structure, the State wishes to implement 352, and 1,250 given an adequate funding

structure.

OVER 300-PERCENT VARIANCE IN SURVEYS

In short, USDA's total is 1,141 schools for the entire country; and, given the inadequate funding structure, the States have told us that there are 4,903 schools, at the very least, that would like to implement the program. Given a decent funding structure-and that is actually what Congress wanted to know: "How many schools actually desire program implementation?"-given that factor, there are 21,720 schools in the country that would like to implement the program, almost 20 times the USDA report to the Congress.

In short, the Department lied to the Congress by grossly understating the need for program expansion. We have found out, unfortunately, that history repeats itself. Like its unsuccessful efforts at deceiving the Congress and State administrators this fall with the School Lunch Program, the Department now seeks to check the expansion of the much-needed School Breakfast Program. But I am hopeful that it is clear that the Department's report to the Congress is a sham; and, I hope that no Senator or Congressman will be deceived by it. Hunger has no place in our Nation's classrooms. Consequently, it is shameful that in our land of plenty, the Depart

ment feels impelled to lie to the Congress in an effort to prevent the appropriation of necessary funds for the eradication of hunger.

RECOMMENDATIONS FOR CHANGE

To remedy the Department's mishandling of the School Breakfast Program, it is crucial that Congress acts quickly, this session, to pass new legislation. Without such new legislation, the program will remain unresponsive to the needs of children and educators throughout the country, and USDA will continue to thwart program expansion. Aside from changing the fiscal structure of the program-as will be detailed by Mr. Irvings in his subsequent testimony-there are seven essential recommendations that I have for legislative change:

"AFFLUENT" SCHOOLS STARVE THE NEEDY

1. The program must be available to all schools in the country.

Currently, the Department has only allowed so-called "needy schools" to participate in the breakfast program. Although the legislation only provides that needy schools should have a priority in program participation (42 U.S.C. S1773 (c)), the Department has strictly prohibited other schools from receiving program funds. This has occurred despite USDA's inability to clearly define what constitutes a so-called "needy school." The tragic result is obvious.

In Fairfax County, Virginia, for example, the Department forced 100 schools to drop out of the program because the concentration of poor children in some of the schools declined as a result of integration. The Department contended that many of the Fairfax County schools were too "affluent" to have a program. The children who lost access to the breakfast program, however, were just as poor, and in as much need of a morning meal in school as they were before the schools were integrated. Furthermore, these children were grouped with children who had access to nutritional adequacy, placing them at a distinct disadvantage in their efforts to keep up with classroom studies.

In order to avoid this and similar problems, new legislation should be passed requiring that all schools seeking program implementation be admitted into the School Breakfast Program.

BYPASS OBDURATE SCHOOL ADMINISTRATORS

2. Private and public agencies should be permitted to operate the breakfast program in areas where the school district has refused to implement the program.

In some areas of the country, school administrators have not yet fully learned about the correlation of hunger and children's inability to learn. Frequently in such areas, church organizations or other civic groups have been willing to operate a child feeding program if they were reimbursed with governmental funds. This has worked out very well in several places such as in California and in Kansas City, Kansas. In order to provide health and education-vital food assistance in such areas, it is essential that new legislation

clearly indicate that such agencies are entitled to operate federallysubsidized breakfast programs whenever local school administrators refuse to do so.

ELIMINATE ERSATZ BREAKFASTS

3. School breakfasts should provide children with proper and adequate food.

Under current legislation, the Secretary of Agriculture has been granted full discretionary powers to determine what meals can be provided under the School Breakfast Program. Unfortunately, the Secretary has grossly abused his powers and has prescribed meals that are nutritionally inadequate. The Secretary's regulations, set forth at 7 C.F.R. S220.8 (a), establish the following nutritional requirements:

A breakfast shall contain, as a minimum, each of the following:

1. One-half pint of fluid whole milk served as a beverage or on cereal or used in part for each purposes.

2. One-half cup serving of fruit or full strength fruit or vegetable juice. 3. One slice of whole-grain or enriched bread; or an equivalent serving of corn bread, biscuits, rolls, muffins, etc., made of whole grain or enriched meal or flour; or 4 cup serving of whole-grain cereal or enriched or fortified cereal; or an equivalent quantity of any combination of these foods.

In determining whether such a meal is adequate, it is important to point out that the literature prepared by eminent nutritionists indicates that breakfasts should provide children with one-fourth to onethird of the Recommended Dietary Allowances-as set forth by the National Academy of Sciences. With this standard in mind, it is clear that the USDA-prescribed meal provides them with only 9 percent of their daily-needed calories; 20 percent of their needed protein; 23 percent of their needed calcium; only 5 percent of their needed iron; 12 percent of their needed Vitamin A; 16 percent of their needed Thiamin; and 9 percent of their necessary Niacin.

To make matters worse, many school districts throughout the country are not even providing children with the USDA-prescribed breakfast, but are providing much less. The Department has done nothing to monitor such program deficiencies. Consequently, as presently administered, the breakfast program virtually assures that needy children will remain malnourished.

USDA has complicated this problem by permitting local districts to provide children with so-called "ersazt breakfasts"-in other words, engineered cakes. Companies such as ITT are deluging the food market with these artificial foods. We think that these "ersatz breakfasts" defeat one of the essential purposes of the School Breakfast Program-the teaching of proper nutrition. Children who eat these cakes are encouraged to eat similar snacks made of empty calories outside of school. The children are unable to distinguish between the artificially-nutritious cakes served in school and the emptycalorie snacks offered at corner stores.

Therefore, our report recommends that "ersatz breakfasts" be eliminated from the program. We further recommend that legislation should specifically require each federally-reimbursed meal to provide at least one-fourth, and preferably one-third, of children's Recommended Dietary Allowances.