NYHealth responded to the U.S. Department of Agriculture’s proposed rule to revise child nutrition programs to make school meal patterns consistent with the 2020 Dietary Guidelines for Americans. The proposed changes would improve the nutrition quality of meals for millions of children, create an environment more conducive to learning, and help promote health equity. NYHealth submitted the following comments:
April 11, 2023
Tina Namian, Director
School Meals Policy Division, 4th Floor
Food and Nutrition Service
1320 Braddock Place
Alexandria, Virginia 22314
Docket ID: FNS-2022-0043
Re: Child Nutrition Programs: Revisions to Meal Patterns Consistent with the 2020 Dietary Guidelines for Americans
Dear Ms. Namian:
The New York Health Foundation (NYHealth) appreciates the opportunity to submit these comments in support of the U.S. Department of Agriculture’s (USDA) Child Nutrition Programs: Revisions to Meal Patterns Consistent with the 2020 Dietary Guidelines for Americans proposed rule (88 FR 8050).
NYHealth is a private foundation that works to improve the health of all New Yorkers, especially people of color and others who have been historically marginalized. Our Healthy Food, Healthy Lives program seeks to advance policies and programs that connect New Yorkers with the food they need to thrive. Improving the quality of food in public institutions, including schools, is a core strategy of this program. Our work has provided us with in-depth knowledge of the challenges and opportunities that school food authorities face, as well as the ways the proposed rule could improve the lives of students across New York State.
NYHealth supports the proposed reductions for added sugars and sodium, increases for whole grains, and expansion in geographic preference standards for the School Breakfast Program (SBP) and the National School Lunch Program (NSLP). The proposed changes would align school meal requirements with the 2020–2025 Dietary Guidelines for Americans (DGAs) and, consequently, improve the nutrition quality of meals for millions of children, create an environment more conducive to learning, and help promote health equity.
1. Strong School Meals Standards Promote Nutrition Security and Learning
The National School Lunch Program and the School Breakfast Program are critical sources of nutrition in children’s diets. Based on a 1,507-person statewide Survey of Food and Health that NYHealth conducted in 2021, we know that in New York State, 3 of every 4 food-insecure households with children cannot afford to feed their children a balanced meal, and more than 80% rely on low-cost foods.[1] Nearly 1.7 million school-age children consume school lunches, and nearly 900,000 children consume school breakfasts in New York annually.[2],[3] These programs provide more than half of some students’ daily calories and are often the healthiest sources of food for school-age children.[4]
Given the critical role that school meal programs play in children’s lives, the Healthy, Hunger-Free Kids Act of 2010 required that these programs align with the DGAs. A recent study suggests that aligning school meal nutrition standards with the 2020–2025 Dietary Guidelines, as the rule proposes, will improve the healthfulness of foods and beverages served and sold in schools; increase participation in school meal programs, which can lead to increased food service revenue and increased food security; and likely improve children’s academic performance.[5]
The updates may also help address health disparities and advance nutrition security among communities of color. Black and Latino children participate in school meal programs at higher rates than white children.[6] They are also more likely to experience hunger. Recent Census Bureau data show that nationally 23% of Black households with children and 21% of Latino households with children experienced food insufficiency in February 2023, compared to 10% of non-Hispanic white households with children.[7] These rates are mirrored in child obesity rates; Black (22.9%) and Latino (22.4%) children experience obesity at nearly twice the rate of white children (13%).[8] Participation in school meal programs is associated with a 14% reduction in the risk of food insufficiency among households with at least one child receiving free or reduced-price lunch.[9] Improving the nutritional quality of school meals through evidence-based nutrition standards promotes health equity.
2. NYHealth Supports USDA’s Proposals to Improve Nutrition Standards and Encourage Local Purchasing
NYHealth supports USDA’s proposals to limit added sugars in school meals. Extensive research links the consumption of added sugars to diet-related chronic diseases including obesity, Type 2 diabetes, fatty liver disease, cardiovascular disease, and dental decay.[10],[11],[12],[13],[14]
Since 2015, the DGAs have recommended limiting added sugar to less than 10% of total daily caloric intake, yet children and adults of all ages exceed this limit. Two recent studies using data from USDA’s School Nutrition and Meal Cost Study (SNMCS) assessed the availability and consumption of added sugars during the school day.[15],[16] These studies found that 92% of school breakfasts contained 10 or more percent of calories from added sugars, as did 69% of lunches. NYHealth supports the limits as written, and recent research suggests that parents will too.[17]
NYHealth applauds USDA’s commitment to reduce sodium in school meals and urges the agency to align the proposed limits with the most recent DGAs. USDA’s proposed changes are a good next step and will help lower children’s sodium intake, but the proposed reductions do not go far enough. USDA should fully align sodium reduction standards with the most recent DGAs, as suggested by advocacy groups like Center for Science in the Public Interest.
Nine out of ten children consume sodium at levels far above the recommended limits. Excess sodium consumption increases children’s risk of developing elevated blood pressure at an early age.[18] It also increases their risk of heart attack, stroke, kidney disease, and premature death later in life.[19], [20] According to a 2018 report from the Centers for Disease Control and Prevention (CDC), approximately one in seven children ages 12–19 years already have elevated blood pressure or hypertension.[21] Under the proposed rule, the average sodium intake for children would continue to exceed the recommended limit.
School food authorities (SFAs) can, over time, meet sodium limits that fully align with the Dietary Guidelines; many have already made significant progress. For example, New York City’s Office of Food and Nutrition Services, the largest SFA in the country, serves approximately 1 million meals a day that meet the City’s stricter food standards.[22] The New York City Food Standards even include sodium limits by food category, an approach that USDA is considering as a best practice. Recommending sodium limits for certain food categories or products could help reduce children’s overall sodium intake. Currently, USDA allows for weekly sodium limits that are intended to give schools more flexibility; weekly menus can include higher sodium products balanced by lower sodium foods on other days. Ironically, this approach can give school nutrition directors less room to prepare healthier, appealing foods on-site. Because the highly processed and pre-packaged items used in school meals are typically high in sodium, the current weekly sodium allowance can leave little room for school nutrition directors to include salt added in the normal course of cooking for items prepared on-site. As a result, scratch-cooked items often may not taste as good to students.
By recommending limits for products known to be high in sodium, USDA could encourage industry to reformulate, and school districts to develop menus that include more appealing meals cooked from whole, fresh ingredients that are naturally lower in sodium.
NYHealth supports USDA’s efforts to encourage whole grain consumption and urges the agency to require that 100% of grain products be whole grain-rich. Whole grain-rich products contain at least 50% whole grains and the remaining grain, if any, is enriched.[23] The 2020 DGAs recommend that at least half of grains consumed be whole.[24] Whole grains are a healthful source of fiber, and their consumption is associated with reduced risk of cardiovascular disease, Type 2 diabetes, and other chronic diseases. [25],[26] Yet the majority of U.S. children ages 5 to 18 do not meet the recommended intake for whole grains and exceed the recommended limit for refined grains.[27] A study conducted this year found that many students who eat both school breakfast and lunch are likely consuming less than half the recommended levels of fiber from school meals.[28]
Waivers during the pandemic may have been needed because of supply chain shortages. But now USDA should send a clear message that children’s health comes first by requiring that 100% of grain products be whole grain-rich.
NYHealth applauds USDA’s continued emphasis on offering a variety of fruits and vegetables in school meals. Child nutrition programs are critical to closing the consumption gap for fruits and vegetables. Nearly a third of young children do not eat fruit daily and almost half do not eat a vegetable daily.[29] Consumption of fruits and vegetables differs by race and ethnicity, age, and household food sufficiency. Most notably, not eating a fruit or vegetable daily was highest among non-Hispanic Black children and lowest among non-Hispanic white children. Since the passage of the Healthy Hunger-Free Kids Act, which mandated an additional cup of fruits and vegetables per day, children’s diet quality has improved overall and across subgroups.[30], [31] School meals are now the healthiest source of food for children.
NYHealth strongly supports USDA’s proposal to expand geographic preference to allow locally grown, raised, or caught procurement specifications for unprocessed or minimally processed food items. Local food systems have multiple economic benefits. Smaller producers keep more of the food dollar when selling to direct markets, and they are more likely to purchase supplies from the surrounding area, further stimulating the local economy. School nutrition departments that had pre-existing relationships with local suppliers also reported fewer supply chain disruptions and more reliable product availability during COVID-19 pandemic-related school closures and ensuing supply chain challenges.
Child nutrition operators overwhelmingly support this provision. Under current procurement rules, smaller food producers have a harder time competing against larger distributors. If implemented, the proposed changes would enable school systems to designate or require within the bid specification that certain food items such as fruits or vegetables be produced locally.
The success of New York’s local purchasing incentive demonstrates how such a change could give local producers an opportunity to more successfully compete for school food contracts. Since its implementation, 87% of schools have reported buying more locally grown fruit, 54% are buying more locally grown vegetables, and 51% are buying more New York milk. In fact, New York schools are now on target to spend more than $250 million on local items and generate nearly $360 million in statewide economic impact by 2025.[32]
3. USDA Should Provide Additional Support to Help Schools Comply with Stronger Nutrition Standards
NYHealth support USDA’s plans to provide technical assistance, share innovative ideas and best practices, provide grants to small or rural SFAs, and encourage collaboration with the food industry. Technical assistance to school food authorities, especially in small and rural districts with demonstrated supply chain issues, will be critical to the rule’s success. We applaud the agency’s recent $100 million investment in the Healthy Meals Incentive Program to support small and rural schools, as well as companies working to reformulate products. Technical assistance funding from Congress, the Healthy Meals Incentive Program, and this rulemaking together present an opportunity to double down on USDA’s commitment to nutrition security.
To maximize the benefit of the proposed changes, USDA should also promote policies and practices that increase school meal participation and consumption. The success of Healthy School Meals for All, also known as universal free school meals, during the pandemic demonstrates the value of access to school meals. Recent research has shown that offering free meals to every student improves access to nutritious school meals and improves equity by eliminating barriers such as filling out meal applications and meeting income-eligibility cut-offs. A systematic review found that universal free school meals increase school meal participation, improve diet quality and attendance, and reduce food insecurity.[33] USDA should continue to communicate these benefits to Congress and encourage states to adopt Healthy School Meals for All in the absence of federal legislative action.
USDA should also promote programs and policies that increase meal consumption, such as providing children with choices in their meal selection, offering pre-sliced or a mix of pre-sliced and whole fruit, limiting availability of competitive foods, and improving the palatability and cultural appropriateness of foods offered.[34] NYHealth’s recent Survey of Food and Health shows that school meals are not meeting all families’ needs equally in New York State. While 81% of white food-insecure families approve of the variety of food school meals provide, less than half of Asian families (37%) do, with Hispanic and Black families’ approval falling somewhere in between.[35] And while two-thirds (67%) of families agree that meals adequately reflect cultural differences and religious dietary needs, still one in three families do not. Groups like Wellness in the Schools (WITS) are working with SFAs to correct this problem. In New York City, WITS has partnered with the New York City Office of Food and Nutrition Services to provide professional development and training to sharpen the District’s ability to prepare fresh-cooked, plant-based, culturally relevant meals like sweet potato gumbo and pineapple fried rice.[36]
Additional policy measures, including lengthening lunch periods and scheduling recess before lunch, have increased food consumption. These measures help to improve focus in the classroom; they more closely align with hunger and satiety cues by accommodating physical activity and allowing ample time for consumption.[37]
4. Conclusion
NYHealth supports USDA’s proposals to improve the nutritional quality of school meals. We encourage USDA to further strengthen the standards for sodium and whole grains. We urge the agency to work closely with the food industry to meet strengthened standards and continue to provide training and technical assistance to school food authorities in need.
Sincerely,
David Sandman, Ph.D.
President and CEO
New York Health Foundation
[1] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/10/food-insecurity-in-families-with-children.pdf. Accessed March 2023.
[2] U.S. Department of Agriculture. National School Lunch: total participation. https://fns-prod.azureedge.us/sites/default/files/resource-files/01slfypart-3.pdf. Accessed February 2023.
[3] U.S. Department of Agriculture. School Breakfast: total participation. https://fns-prod.azureedge.us/sites/default/files/resource-files/08sbfypart-3.pdf. Accessed February 2023.
[4] Liu J, Micha R, Li Y, Mozaffarian D. Trends in food sources and diet quality among US children and adults, 2003-2018. JAMA Netw Open. 2021;4(4):e215262.
[5] Miller L, Lott M, Story M. Rapid health impact assessment on changes to school nutrition standards to align with 2020-2025 Dietary Guidelines for Americans. Healthy Eating Research. 2023. https://www.healthyeatingresearch.org. Accessed February 2023.
[6] U.S. Department of Agriculture. School nutrition and meal cost study: volume 4. 2019. https://fns-prod.azureedge.us/sites/default/files/resource-files/SNMCS-Volume4.pdf. Accessed February 2023.
[7] U.S. Census Bureau. Food sufficiency for households with children in the last 7 days by select characteristics. Household Pulse Survey: February 1 – February 13. https://www2.census.gov/programs-surveys/demo/tables/hhp/2023/wk54/food2_week54.xlsx. Accessed February 2023.
[8] State of Childhood Obesity. Explore data by demographic: ages 10-17. Robert Wood Johnson Foundation. https://stateofchildhoodobesity.org/demographic-data/ages-10-17/. Accessed February 2023.
[9] Huang J, Barnidge E. Low-income children’s participation in the National School Lunch Program and household food insufficiency. Soc Sci Med. 2016 Feb;150:8-14.
[10] Malik VS, Popkin BM, Bray GA, Després J-P, Hu FB Sugar-sweetened beverages, obesity, type 2 diabetes mellitus, and cardiovascular disease risk. Circulation. 2010;121:1356–1364.
[11] Neuenschwander M, Ballon A, Weber KS, Norat T, Aune D, Schwingshackl L, Schlesinger S. Role of diet in type 2 diabetes incidence: umbrella review of meta-analyses of prospective observational studies. BMJ. 2019. 366:l2368.
[12] Yang Q, Zhang Z, Gregg EW, Flanders WD, Merritt R, Hu FB. Added sugar intake and cardiovascular diseases mortality among US adults. JAMA Intern Med. 2014;174(4):516-24.
[13] Chi DL, Scott JM. Added sugar and dental caries in children: a scientific update and future steps. Dent Clin N Am. 2019;63:17-33.
[14] Bleich S, Vercammen K. The negative impact of sugar-sweetened beverages on children’s health: an update of the literature. BMC Obes. 2018;5:6.
[15] U.S. Department of Agriculture, Food and Nutrition Service. Added sugars in school meals and competitive foods: a report to Congress. 2022. https://fns-prod.azureedge.us/sites/default/files/resource-files/AddedSugarsinSchoolMeals.pdf. Accessed February 2023.
[16] Fox MK, Gearan EC, Schwartz C. Added sugars in school meals and the diets of school-age children. Nutrients. 2021;13(2).
[17] Sohlberg TM, et al. Parent perceptions of school meals in the San Joaquin Valley during COVID-19: a photovoice project. Nutrients. 2023;15(5):1087.
[18] Rosner, et al. Childhood blood pressure trends and risk factors for high blood pressure: the NHANES experience 1998-2008. Hypertension. 2013;62:247-254.
[19] Lawes CM, et al. Global burden of blood pressure-related disease, 2001. Lancet. 2008 May 3;371(9623):1513-8.
[20] Appel LJ, et al. Reducing sodium intake in children: a public health investment. J Clinic Hypertension. 2015;17(9):657-662.
[21] Jackson SL, et al. Hypertension among youths —United States, 2001–2016. MMWR Morb Mortal Wkly Rep. 2018;67:758–762.
[22] N.Y.C. Department of Health. New York City food standards. 2022. https://www.nyc.gov/assets/doh/downloads/pdf/cardio/cardio-meals-snacks-standards.pdf. Accessed March 2023.
[23] U.S. Department of Agriculture, Food and Nutrition Service. Grain requirements for the National School Lunch Program and School Breakfast Program. April 26, 2012. https://www.fns.usda.gov/cn/grain-requirements-national-school-lunch-program-and-school-breakfast-program#:~:text=Whole%20grain%2Drich%20products%20must,if%20any%2C%20must%20be%20enriched. Accessed March 2023.
[24] U.S. Department of Agriculture, U.S. Department of Health and Human Services. Dietary Guidelines for Americans, 2020- 2025. 2020. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf. Accessed March 2023.
[25] U.S. Department of Agriculture. All about the grains group. https://www.choosemyplate.gov/eathealthy/grains. Accessed March 2023.
[26] Seal CJ, Brownlee IA. Whole-grain foods and chronic disease: evidence from epidemiological and intervention studies. Proc Nutr Soc. 2015 Aug;74(3):313-9.
[27] U.S. Department of Agriculture, U.S. Department of Health and Human Services. Dietary Guidelines for Americans, 2020- 2025. 2020. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf. Accessed March 2023.
[28] Chapman LE, et al. Nutrient content and compliance with sodium standards in elementary school meals in the united states pre- and post-COVID-19. Nutrients. 2022;14(24):5386.
[29] Hamner HC, et al. Fruit, vegetable, and sugar-sweetened beverage intake among young children, by state—United States, 2021. MMWR Morb Mortal Wkly Rep. 2023;72:165–170.
[30] Liu J, Micha R, Li Y, Mozaffarian D. Trends in food sources and diet quality among US children and adults, 2003-2018. JAMA Netw Open. 2021;4(4):e215262.
[31] Cohen JFW, Richardson S, Parker E, Catalano PJ, Rimm EB. Impact of the new U.S. Department of Agriculture school meal standards on food selection, consumption, and waste. Am J Prev Med. 2014;46(4):388-394.
[32] Ruiz-Ramon M. Investing in farm to school in New York is an A+ policy. American Farmland Trust. 2021. https://farmland.org/farm-to-school-in-new-york-policy-blog/. Accessed March 2023.
[33] Cohen JFW, Hecht AA, McLoughlin GM, Turner L Schwartz MB. Universal school meals and associations with student participation, attendance, academic performance, diet quality, food security, and body mass index: a systematic review. Nutrients. 2021;13:911.
[34] Cohen J, Hecht A, Schwartz M. Promising and low-cost strategies to improve school meal consumption. Healthy Eating Research. October 2021. https://healthyeatingresearch.org/wp-content/uploads/2021/10/HER_ConsumptionBrief_final.pdf. Accessed March 2023.
[35] New York Health Foundation. Survey of food and health. August 16, 2022. https://nyhealthfoundation.org/wp-content/uploads/2023/01/NYHealth-survey-of-food-and-health.pdf. Accessed March 2023.
[36] New York Health Foundation. Our grantees: Wellness in the Schools. December 14, 2022. https://nyhealthfoundation.org/grantee/wellness-in-the-schools/. Accessed March 2023.
[37] Cohen JFW, Hecht AA, Hager ER, Turner L, Burkholder K, Schwartz MB. Strategies to improve school meal consumption: a systematic review. Nutrients. 2021;13(10):3520.
