And Away We Go Presenting SNA’s 2014 Position Paper on Federal Child Nutrition Programs. Federal child nutrition programs provide more than 30 million school lunches and 13 million school breakfasts to students daily. In addition, these federal programs include other critical food assistance for children, such as summer meals, afterschool snacks and suppers. The members of the School Nutrition Association (SNA) are committed to providing nutritious, appealing and affordable meals which fuel students to succeed academically and thrive physically. The Healthy Hunger-Free Kids Act (HHFKA) of 2010 and subsequent regulations made a number of significant changes to the programs intended to improve the health of school children. However, following partial implementation of the HHFKA and the regulations, program costs soared, administrative burdens increased and student participation in the school lunch program declined by more than one million meals per day. Given today’s financially challenging environment, access to child nutrition programs remains a high priority for America’s families. As we move toward Child Nutrition Reauthorization 2015, SNA remains committed to the core principles of: ■ promoting a healthy school environment for children; ■ providing reasonable flexibility in the operation of school meal programs; ■ maximizing program efficiency; and ■ ensuring overall sustainability of child nutrition programs. Considering these core principles, the School Nutrition Association advocates for the following actions: Meal Pattern Flexibility Retain the initial requirement that 50% of grains offered through school lunch and breakfast programs be whole-grain rich. This action would ease declines in participation and provide reasonable flexibility. The 2010 Dietary Guidelines for Americans allows for the consumption of some refined grains. Talking Points: While many students have adjusted to whole-grain-rich breads, schools nationwide have struggled to find specialty whole-grain-rich items (such as tortillas, biscuits and pastas) that students accept. Other challenges include limited availability of such products in rural areas and strong regional preferences for refined grains, such as white rice or tortillas. Schools have experienced significant plate waste, increased costs and decline in student participation due to rejection of specific whole-grain products. Retaining the current 50% requirement will ensure students continue to receive a variety of whole-grain items. Suspend the implementation of sodium Target 2 pending the availability of scientific research that supports the reduction in daily sodium intake for children. The Institute of Medicine’s (IOM) School Meals: Building Blocks for Healthy Children report, commissioned by the U.S. Department of Agriculture (USDA) and released in 2009, recommended assessing the progress and effects of sodium reductions on student participation rates, food cost, safety and foodservice operations. Talking Points: Schools are already making significant reductions to sodium in school meals to meet the first target. The IOM report noted that “it would be appropriate to assess progress and [the] effects of the actions on student participation rates, food cost, safety and foodservice operations to determine a reasonable target for the next period.” The authors went on to note that reducing sodium content in an acceptable way for students “will present major challenges and may not be possible.” Naturally occurring sodium present in milk, meats and other foods make the later targets extremely difficult to achieve. In addition, more scientific research should be done on the efficacy of further reducing children’s sodium intake. Remove the requirement that all students must select a half-cup serving of a fruit or vegetable as part of a reimbursable breakfast and/or lunch. This requirement has led to increased program costs, plate waste and a decline in student participation. Talking Points: Some students simply do not want to take a fruit or vegetable with their meal, and the subsequent plate waste was not an intended consequence of this requirement. Through nutrition education programs, sampling activities and other cafeteria initiatives, schools are encouraging students to choose produce with the meal. Competitive Foods Reopen and extend the comment period on the “Smart Snacks in School” Interim Final Rule until July 2015. Extending the comment period would allow stakeholders at all levels (national, state and local) to collect data to assess the impact of the rule during the first year of implementation and provide USDA the opportunity to make reasonable, responsible, evidence-based adjustments to the final rule. Talking Points: When it permanently repealed the weekly grain and proteins limit originally established in the meal pattern, USDA acknowledged that such a requirement created unintended problems at implementation. The new Smart Snacks in Schools rule is just as complex and challenging to implement as the new meal pattern, and is likely to produce unintended consequences. Strengthening School Meal Programs Encourage a clear and coordinated strategy between the USDA and the U.S. Department of Education to achieve a school environment supporting students’ health, well-being and academic success. Joint efforts are essential to address adequate time for students to consume meals and for the development of curriculum that supports a healthy school environment. Talking Points: Scheduling and length of the time to eat school meals have returned to the spotlight, as local districts continue to struggle with complex scheduling challenges. These can be complicated by high enrollments in facilities that simply cannot accommodate large numbers of students arriving at the cafeteria at the same time. Recent media reports have identified some lunch periods scheduled as early as 9:30 a.m. In addition, the operational limitations to get all students through the line can mean that a child has less than 10 minutes to consume the meal. This is far from optimal for both nutrition and education purposes. Also, to effect sustainable changes in health and wellness, nutrition messages established in the cafeteria must be supported elsewhere in the school. Partnerships to explore innovative approaches should be encouraged. Return to the five-year administrative review cycle. State agencies overseeing school meal programs do not have adequate staff and resources to effectively sustain the new three-year administrative review cycle under the HHFKA. Returning to the five-year administrative review cycle would allow state agencies to provide school food authorities (SFAs) greater support and guidance as they work to meet new standards. Talking Points: The three-year cycle has drastically increased the amount of time that state agency staff spend out of the office conducting site reviews, instead of offering training and technical assistance. Address the problem of unpaid meal charges. Unpaid meal charges by students continue to increase. USDA should fully implement the requirements of the HHFKA to examine and report on this issue and then implement regulations that effectively address debt arising from unpaid meal charges. Talking Points: Some schools have accumulated substantial unpaid meal debts that can hamper their ability to meet nutrition standards for school meals. Currently, individual school districts must determine if students will receive alternate or unpaid meals, how many meals can be charged and how to handle meal charge debts. These policies are unpopular and misunderstood by the public and can lead to negative media attention that damages the program as a whole. Increase program simplification. As Congress drafts and USDA implements the 2015 Child Nutrition Reauthorization, efforts should be made to simplify child nutrition programs, easing the administrative and paperwork burdens on SFAs. Talking Points: The complex regulatory burden on school meal programs is a challenge, especially for many of the operators charged with compliance at the school site level. While training guidelines proposed by USDA may prove helpful upon implementation, the lack of funding and resources to provide such training and development may prove another barrier to success. Provide flexibility on Paid Meal Equity. Section 205 of the HHFKA mandates that SFAs increase their paid meal prices regardless of their financial solvency. Congress should allow local flexibility by narrowing Section 205 to include only those SFAs that have a negative fund balance at the end of the previous school year. Talking Points: School meal prices, just like restaurant prices, differ greatly from one community to the next. When setting these prices, school boards must take into account local food and labor costs, as well as what families are able and willing to pay. When school meal prices increase, even gradually—and especially at the same time as changed nutrition standards—many students start packing lunch or buying from nearby fastfood and convenience sites. Certainly, decreased participation and reduced reach of important nutrition messages were not the intended consequences of this provision. Setting Forth on a New Road Welcome to School Nutrition’s new “Road to Reauthorization” column. As many readers know, several federal child nutrition programs require reauthorization by Congress every five years. Although the National School Lunch Program, as an entitlement program, is officially exempt from this congressional step, advocates for school meal programs use the occasion of reauthorization as an opportunity to lobby for legislative actions intended to improve the operation and administration of all the school meal programs. After Congress has passed a reauthorization bill and it is signed into law, it is up to the U.S. Department of Agriculture (USDA) to follow the provisions established in the legislation and set corresponding regulations. The Healthy, Hunger-Free Kids Act of 2010 was the last reauthorization bill; the next reauthorization of the federal child nutrition programs is expected to take place in 2015. SNA relies on the grassroots advocacy power of its 54,000 members and its industry partners to speak up and tell federal legislators about the top concerns and priorities for school nutrition programs. The Association has a long history of applying an inclusive and transparent process to gather input and feedback in setting its legislative agenda and empowering members to drive it home. With a new team working as our legislative counsel and guided by a comprehensive three-year legislative plan, SNA has begun the long reauthorization process. Over the course of the next two years, this column will feature insightful reports on how that process is coming together—and how School Nutrition readers can play a part. This month’s column, focused on SNA’s new 2014 Position Paper on Federal Child Nutrition Programs, represents the first official step toward the 2015 Reauthorization. Taking Action Did you attend SNA’s Legislative Action Conference this month? Don’t forget that this annual gathering in the nation’s capital is not your only opportunity to speak up and share your story with members of Congress. Successful legislative advocacy is a year-round effort. Stay tuned for updates on SchoolNutrition.org and published in Tuesday Morning, SNA’s weekly web-based policy and awareness e-newsletter. Each week, you’ll receive up-to-date legislative and regulatory news, as well as a sampling of child nutrition program media coverage. Visit www.schoolnutrition.org/tuesdaymorning to sign up!
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