For over 65 years, the U.S. Department of Agriculture has purchased commodity foods for the National School Lunch Program (NSLP) in an effort to support both schools and food producers. Based on data from 339 Minnesota school districts from 2001–2008, this research examined whether the NSLP's in-kind food program is an efficient and equitable way to fund school food services. Multivariate models suggested that the program is inefficient, though offered limited insight into district-level factors that affected utilization of commodity funding, and therefore offered less clear conclusions about equity. It was estimated that districts obtained just $0.60 in commodity food value given a $1 increase in available commodity funding over the years observed, and that the commodity program's system of “reconciled” and “rollover” funding accounted for much of this discrepancy. Based on these results, it is recommended that a cash benefit replace the NSLP's current in-kind food benefit for schools.

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