New forms of non-legislative government action have proliferated over the last 50 years, expanding the array of bureaucratic "tools of government. Guidelines issued by federal agencies are a tool used to recommend, rather than mandate, state and local government action. The intergovernmental nature of guidelines, lack of penalty for non-compliance, and reliance on bureaucratic or scientific expertise to develop content makes guidelines unique. This study examined guidelines from the federal Centers for Disease Control and Prevention in the 1990s recommending state adoption of school health policies for nutrition, physical activity, and tobacco. With cross-sectional data from the School Health Policies and Programs Study 2000, an index was created to assess the number of guidelines that were adopted as state-level policies. Correlation and multiple regression analyses of the 50 States and District of Columbia were used to compare adoption of CDC guidelines with adoption of legislation reported in the literature. Using the framework of diffusion of innovations theory, analyses identified the District of Columbia and the state of Alabama as consistent national leaders in the number of CDC guidelines adopted. Analyses by geographic region also indicated consistent leaders and laggards within regions across the three substantive policy areas, with western states showing overall lower levels of policy adoption. An internal determinants model showed that characteristics such as state size, per capita income, and state liberalness were unrelated to guideline adoption levels. Overall, results suggest that guidelines adoption follows markedly different patterns from legislation. Study findings further suggest that analyses which combine policies to seek across-the-board determinants may obscure key determinants that are policy- or issue-specific. The strength of scientific evidence underlying a policy is suggested as a new variable for inclusion in future studies.