SNA’s 2015 Position Paper Setting legislative priorities for the next CNR. After months—indeed years—of discussing the 2015 Child Nutrition Reauthorization (CNR), the time to act is here. The Healthy, Hunger-Free Kids Act of 2010 (HHFKA) expires on September 30 of this year, and to ensure continuation of a number of the federal school-based child nutrition programs, Congress must reauthorize them. Reauthorization is also an opportunity to legislate changes that affect the operation and administration of these programs. SNA has released its 2015 Position Paper to set forth its CNR priorities as the legislative process gets underway this month at its annual Legislative Action Conference (LAC) in Washington, D.C. The Paper was crafted with input from the Association’s 55,000 members. [Editors’ Note: See “The Right Touch for the Write Stuff,” February 2015, to go behind the scenes of that process.] While SNA members support strong federal nutrition standards, many of the regulatory requirements and implementation timelines that came out of the HHFKA found school nutrition operators facing growing NSLP costs, rising plate waste and declining participation to the tune of 1.4 million children. In light of these challenges, as Congress considers the 2015 CNR, SNA members look forward to sharing their expertise with lawmakers, demonstrating their commitment to these key principles: • ensuring students have access to nutritious, appetizing meals; • promoting healthy school environments; • simplifying regulations and providing flexibility to maximize efficiency and ease administrative burdens; • restoring financial sustainability of school meal programs, which operate independent of school district budgets. As detailed in the 2015 Position Paper, SNA advocates for the following seven actions: 1. Increase the per-meal reimbursement for both school breakfast and lunch by 35 cents to ensure School Food Authorities (SFAs) can afford to meet federal requirements. When HHFKA was passed in 2010, Congress provided an additional 6-cent performance-based reimbursement for schools that met the new nutrition standards for lunch. But no additional funds were established for breakfast, despite USDA’s stated expectation of significant cost increases for both meals. Since 2010, rising food and labor costs overall, coupled with those directly associated with the requirements of the new standards, have drastically increased the cost of preparing school meals. With revenues on the decline, due to reduced participation in both reimbursable meal and a la carte service, many SFAs are seeing a genuine threat to the financial sustainability of these meal programs. 2. Maintain the Target 1 sodium level reductions and suspend implementation of further targets. With significant effort, schools have met the Target 1 sodium reductions. However, before advancing to Target 2, the Institute of Medicine recommended assessing the impact of Target 1 “on student participant rates, food cost, safety and foodservice operations to determine a reasonable target for the next period … reducing the sodium content of school meals as specified and in a way that is well accepted by students will present major challenges and may not be possible.” In addition, naturally occurring sodium in foods such as milk and meats could force schools to take healthy choices off the menu. For example, a small turkey wrap, prepared with USDA Foods turkey and tortillas and served with USDA Foods low-sodium green beans and milk, exceeds Target 2 limits for all grade levels. 3. Grant individual SFAs the authority to decide whether students are required to take a fruit or vegetable as part of a reimbursable meal. SNA supports offering a greater variety and quantity of fruits and vegetables; however, some students do not want a fruit or vegetable with every single meal or don’t want the particular choice being served. The requirement that a student must take a half-cup with every breakfast and lunch has increased both waste and costs, leaving schools with little room in their budget to invest in appealing—yet more expensive— product choices, such as berries and kiwi. Researchers from Cornell University and Brigham Young University found that forcing students to take a fruit or vegetable with every meal, even if they don’t intend to eat it, has increased waste by 100%, with an estimated $684 million of fruits and vegetables being thrown in the trash each school year. SFAs know best whether this mandate has been beneficial or detrimental in their schools, and they should be allowed to decide whether students are required to take a fruit or vegetable with each meal. 4. Restore the initial requirement that at least half of grains offered through school lunch and breakfast programs be whole grain-rich. Schools have struggled to procure acceptable whole-grain specialty items, such as tortillas and biscuits. In rural areas, whole grain-rich items are limited in availability; across the country, whole grain-rich items are higher in cost and not as easily accepted as refined grain items. SNA supports the July 2012 requirement that half of all grains offered with school meals must be whole grain-rich. The 2014 mandate, though, that that all grains must be whole grain-rich, has increased waste and contributed to the decline in student lunch participation. Schools should be permitted to serve white rice or tortillas on occasion, just like most families do at home. Restoring the requirement that half of all grains offered be whole grain-rich will ensure students continue to receive a variety of whole-grain choices in school, while limiting waste. 5. Allow all food items that are permitted to be served as part of a reimbursable meal to be sold at any time as an a la carte item. The Smart Snacks in School rule forced schools to take many healthy school menu options off a la carte menus. In part this is because while school meal standards gradually phase in sodium reductions over 10 years, Smart Snacks rules do not, forcing competitive foods to meet excessively low sodium limits. For example, a 2-oz. eq. of USDA Foods reduced-sodium ham without bread, cheese or condiments nearly exceeds the Smart Snacks sodium limit for the total entrée, while one cup of low-sodium peas exceeds the side dish limit. Even salads have taken a hit, as the sodium in lowfat dressing often exceeds limits. Allowing foods that meet nutrition standards for school meals to be sold as daily competitive food choices can help preserve the financial stability of school meal programs and ensure students can choose from a variety of healthy choices in the cafeteria. 6. Modify Section 205, Paid Lunch Equity of the HHFKA, by exempting SFAs that had a positive fund balance at the end of the previous school year. Section 205 requires many SFAs to increase paid meal prices, regardless of local situations. School meal prices, just like restaurant prices, differ from one community to the next, as schools must take into account local food and labor costs and what families are able and willing to pay. When school meal prices increase, even gradually, student lunch participation declines. Recognizing problems with this rule, USDA offered a temporary exemption for SFAs in strong financial standing. SNA requests a permanent exception to the rule for all SFAs that have a positive fund balance at the end of the previous school year. This would narrow Section 205 to apply only to SFAs with a negative fund balance. 7. Provide program simplification. As Congress drafts and USDA implements the 2015 CNR, prompt action must be taken to simplify child nutrition programs and ease administrative burdens on SFAs and state agencies. The overwhelming complexity of program regulations and administrative requirements is hindering efforts to better serve students.
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