It could be tricky if it goes through. The definitions are too broad. Thier biggest concern are schools that dont meet meal best practices, but if yhey are already not meeting those, why would they substantially follow these?
Also how far reaching would this be? The school I work at, if they pre slice apples, they add some pineapple juice to help prevent them oxidising, that seems to run afoul of the letter of the law. and the HS I went to, it was a small place, independent study program. So kids where there 2 hours a week, there was no cafeteria. The school kept kraft mac and cheese, instant ramen and some other things if any kid was hungry, that certainly would run afoul but the alternative is just not to have any food available?