Is our district powerless to lengthen lunch? (Part two)

Yesterday I wrote (again) about our school district’s paltry fifteen-minute elementary school lunch period. When I complained about it, the superintendent repeatedly cited a state regulation requiring 27.5 hours of instructional time per week. Because of that requirement, the superintendent argued, the district cannot possibly devote even ten more minutes to lunch without lengthening the school day.

That sounded funny to me. When I looked at my own kids’ schedules, compliance with that regulation seemed to hinge entirely on whether recess counts as instructional time. If it does, then there’s ample time left over to lengthen lunch. If it doesn’t, then the district is already failing to meet the state’s requirement of 27.5 hours of instructional time per week.

So a few days ago I emailed the state Department of Education and asked how the Department interprets the requirement. The response was that yes, recess counts as instructional time. (See the full exchange below.) The regulation also expressly states that passing time between classes counts as instructional time. Only lunch is expressly excluded from the calculation.

My kids go to school for 31.5 hours each week. The state requires them to get 27.5 hours of instructional time each week. That leaves four whole hours, doesn’t it? If everything but lunch counts as instructional time, couldn’t lunch be as long as forty-eight minutes without violating the state requirement and without lengthening the school day?

Am I missing something? Can someone please explain how the 27.5-hour instructional-time requirement has any bearing whatsoever on whether our district could add ten or fifteen (or even thirty!) minutes to the lunch period?

Part three here. To read my email exchange with the state Department of Education, click on the “Continue Reading” link.


My email to the Jason Glass, the Director of the State Department of Education:

Hi – I’m writing to ask about the state requirement governing elementary school instructional time. Specifically, I’m wondering how the DOE interprets Iowa Admin. Code 281-12.1(9), which states that “A school day shall consist of a minimum of 5½ hours of instructional time for all grades 1 through 12.”

My question is whether recess is counted as instructional time for purposes of that regulation. I thought it might be, for three reasons: (1) recess has educational value; (2) the regulation specifically excludes lunch from the definition of instructional time, but contains no similar exclusion of recess, and (3) the regulation recognizes some other activities as instructional time even though no explicit instruction is occurring (for example, passing time between classes), and even though the child may not even be present (for example, parent-teacher conferences).

Can you tell me how the DOE interprets the regulation on that question (or forward this email to the proper person to ask)? Thank you for any information you can provide,

He forwarded my email to Policy Liaison Mike Cormack, who replied:

Chris and Jason,

According to Carol Greta, our legal counsel with great institutional memory, recess does count for the reasons cited in the initial email. I hope this is helpful on your end and don’t hesitate to contact with any additional questions-

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