The U.S. Department of Agriculture proposed and adopted a new set of meal pattern requirements for the National School Lunch Program that will allow schools to claim 6 cents more in lunch reimbursement rates. This study analyzes the food costs of school menus in 2005 that met many of the proposed requirements. Overall, schools that served more, and more diverse, non-starchy vegetables had higher average food costs, and schools that served menus with lower calories had lower food costs. The food costs of school lunch menus that met the combined standards for dark green vegetables, orange vegetables, other vegetables, lowfat/fat-free milk, and fruit averaged 9 cents more per meal in 2005 dollars when other major factors that could affect food choices are taken into account. The main sources of higher costs appear to be related to the provisions for more vegetables.