Objective

To determine whether the Department of Agriculture and Markets is adequately administering the 30% New York State Initiative to ensure that New York State food products are provided to children as part of their lunch meal in school, while also supporting local farmers and the local economy. The audit covered the period from July 2022 through June 2025.

About the Program

New York State households with children have experienced the highest rates of food insecurity since 2020—as high as 16% in 2022. Even with lower rates of food insecurity in the first 3 months of 2024, roughly one in nine families with children in New York reported they sometimes or often do not have enough to eat due to lack of money or other resources.¹

Providing meals for students is a strategy to reduce food insecurity, support learning, and improve physical health if the meals provided are high quality and healthy. The Department of Agriculture and Markets (AGM), through its Food and Nutrition Unit, administers the 30% New York State Initiative (Initiative). Established under Chapter 56 of the Laws of 2018, the Initiative is intended to provide healthy New York-sourced food products to children as part of their lunch meal in school. Annually, $10 million is appropriated to support the Initiative, which provides School Food Authorities (SFAs)—entities responsible for the administration and operation of school food programs—with reimbursement for school lunch meals. The Initiative increases the reimbursement schools receive for lunches from 5.9 cents per meal to 25 cents per meal. SFAs are eligible to participate in the Initiative when at least 30% of their total food costs for lunches in the preceding school year² is spent on eligible State-produced and -processed food products. SFAs must apply to AGM annually to participate in the Initiative. Applications are due in August, and SFAs must submit all child nutrition reimbursement claims from the previous school year prior to completing their applications. SFAs report information from the previous school year’s food purchases on the application. Beginning with the 2022-23 school year, AGM developed an audit function that included conducting a review of the documents SFAs used to qualify for the Initiative, such as documentation relating to how the SFAs calculated that they meet the Initiative and supporting information for total annual food costs. As of June 12, 2025, for the 2024-25 school year, 73 SFAs were reimbursed approximately $2.9 million under the Initiative.

Key Findings

AGM is adequately fulfilling its responsibility to administer the Initiative; however, we found areas AGM could improve to enhance participation and access to eligible food products. Further, AGM could improve practices to increase assurance that the Initiative funds eligible foods that support local farmers and provide healthy choices for children, and to reduce certain administrative burdens on SFAs. Specifically:

• Although the Initiative was established over 7 years ago, and despite incremental increases since AGM became the lead agency in 2022 (taking the lead from the State Education Department), participation by SFAs remains relatively low. There are 762 SFAs eligible to participate in the Initiative outside New York City; however, only 73 (10%) have been approved for reimbursement under the Initiative, and just $2.9 million of the $10 million (29%) appropriated had been reimbursed for the most current school year (2024-25) to SFAs as of June 2025. SFA officials cited several barriers, but the most common reason cited was the administrative burden of having to account for school lunch costs separately from other food costs, such as breakfast or snacks. Of the 758 SFAs we surveyed, 253 responded. Of the 253 SFAs, 106 (42%) cited the administrative burden as an issue; however, several other factors were noted as well. For example, 60 (24%) cited difficulty sourcing eligible products from farms and distributors and 41 (16%) raised concerns over the cost of eligible products. While expanding the Initiative to include food costs other than lunch and increasing the reimbursement rate to align more with increases in food costs could only be made through legislative change, AGM could reduce some of the administrative burden built into the Initiative and improve access to eligible foods by connecting SFAs with suppliers and distributors or developing other resources to assist with sourcing eligible foods.
• Although AGM has developed a process to review and approve applicants, we found it could be improved if AGM required SFAs to include support for the total annual food costs incurred, allowing AGM the ability to verify the 30% calculation necessary to determine eligibility during the application process. AGM only required SFAs to submit supporting documentation for the total annual food costs during an audit but not with the application. Because the total annual food cost is a key number to determine if the SFA qualifies for the Initiative, without documentation to support this number, AGM cannot be certain a school qualifies unless AGM conducts an audit.
• To reduce the administrative burden on both AGM staff and SFAs, we identified areas within AGM’s audit process that could be simplified or streamlined. We found that AGM did not standardize documentation requirements that SFAs use to support food costs, which may have contributed to errors in calculating eligibility percentages by SFAs or lack of support for costs. We reviewed 30 audits performed by Cornell Cooperative Extension and AGM and found four instances (13%) where support for total annual food costs was not found in documentation provided by the SFA and another seven instances (23%) where the total annual food costs provided by the SFA were incorrect, causing discrepancies in the application numbers related to total annual food costs and calculation of eligibility percentage.

Key Recommendations

• Take steps to improve participation in the Initiative, which may include but not be limited to: continuing or increasing outreach and assistance efforts; reducing the administrative burden and streamlining requirements where practicable; and developing and maintaining information to assist SFAs with identifying and purchasing eligible food products.
• Improve the administration of the Initiative, which may include but not be limited to: requiring SFAs to submit support for total food costs as part of the application process; providing guidance on documentation requirements to support eligible food costs; and standardizing and streamlining documentation requirements as practical.

1 https://www.osc.ny.gov/reports/food-insecurity-persists-post-pandemic
2 A school year is the period July 1 through June 30.