It’s National School Breakfast Week, and the Trump administration is celebrating by rolling back science-based nutrition standards that are keeping kids healthy at school.
(Not that it takes a special occasion to pull the plug on policies that protect children’s health.)
This is the second time the administration has taken aim at the nutrition standards put in place by the Healthy, Hunger-Free Kids Act of 2010, the bipartisan landmark legislation that brought school meals in line with evidence-based dietary guidance for the first time. By many measures, the standards have been a success: kids are getting more fruits, vegetables, and whole grains on their lunch trays, and less added sugar, saturated fat, and sodium; schools with healthier meals are seeing higher participation in school breakfast and lunch programs; and food waste hasn’t increased in the process (although across the board, we still waste too much food just about anywhere we eat, prepare, or serve it). What’s more, 99 percent of schools were successfully meeting most of the new standards by 2016.
Yet here we are. If this particular proposal passes in its current form, it would deliver another blow to one of the most powerful tools at our disposal to promote health and prevent obesity among the nation’s youth—especially those who rely on school meals the most.
Introducing the new National School Potato Program
Okay, that’s not a thing, but it’s also not as ridiculous as it sounds.
Here’s why: the proposed rule would allow schools to swap out the required one cup of fruit at breakfast for one cup of any type of vegetables, and would provide schools more flexibility in choosing the types of vegetables that can be used to meet weekly minimum requirements at lunch. (In the school lunch program, vegetables are categorized as dark green, red/orange, beans and peas, starchy, or other, with minimum weekly requirements for each.) In theory, this means schools could choose to serve a starchy vegetable like a potato every day at breakfast and most days at lunch. By taking advantage of these flexibilities, in addition to a proposed change related to legumes, a student could be served as many as eight and a half cups of potatoes every single week.
For the record, I’m not suggesting we banish potatoes from lunchrooms. They have their place on our plates (even in fried form, on occasion). But the purpose of nutrition standards is to help schools develop menus that offer a variety of fruits, vegetables, whole grains, and other healthy foods that meet kids’ nutritional needs, and eight and a half cups of tater tots a week just isn’t going to cut it.
Among other changes, the proposed rule would also allow more processed meat to be served at breakfast and more foods like pizza and hamburgers to be sold à la carte, exempt from nutrition standards. A prior rule that went into effect in early 2019 already halved whole grain requirements, allowed more varieties of flavored sugar-sweetened milk, and prevented sodium reduction targets from moving forward.
The good news? None of these rule changes are requirements; they’re just options that schools can exercise at their discretion. This means that some schools, particularly those with well-resourced food service departments, will see little change in their menus. It’s also likely that some of the proposed flexibilities, including certain administrative changes, could reduce waste and streamline food service without significantly impacting the nutritional quality of meals.
But the bad news is still pretty bad. When exercised to their fullest extent, as cost-saving measures or otherwise, these flexibilities could substantially diminish the healthfulness of school meals.
When school meals are less healthy, health equity takes a hit
When school meals are less healthy, it isn’t good for any of our kids. But, as with previous policies eroding public health protections, the effects could be drastically worse for children from low-income families and children of color.
As we wrote in our public comment to the US Department of Agriculture (USDA), the vast majority of children who eat breakfast and lunch at school are from low-income households: nearly 75 percent of lunches and 85 percent of breakfasts are served to these students at reduced or no cost. For most kids, these meals make up about half of the total calories they’ll eat in a day, and studies suggest this proportion is likely higher among kids who experience food insecurity at home—meaning school food plays a particularly important role in providing both calories and key nutrients.
The relationship between poverty and race in the United States, forged through a long history of racist policies and practices, also means that children of color are more likely to participate in school meal programs. And regardless of income level, children of color also face unique challenges to eating healthfully as a result of unhealthy food marketing, which is itself a contributor to poor diets and diet-related disease. Findings from the University of Connecticut’s Rudd Center for Food Policy and Obesity have shown that restaurants and food and beverage companies disproportionately market their least nutritious products, including fast food, candy, sugary drinks, and snacks, to Black and Hispanic youth.
Studies have shown that the nutrition standards implemented by the Healthy, Hunger-Free Kids Act of 2010 were effective in reducing disparities in the healthfulness of foods served across different schools, including those that were predominantly white and those that weren’t. Rolling back science-based standards could put these critical measures of progress at risk, threatening to worsen existing health disparities and putting millions of children on a path to poorer health.
What happens next?
The USDA is accepting public comments on the proposed rule through March 23.
Submit your own comment here, and refer to our public comment guide for sample talking points and tips for writing an effective comment. You can find the full version of the comment we submitted on behalf of UCS below.
With any luck (and a lot of civic engagement), we’ll have something very different to celebrate the next time National School Breakfast Week rolls around.
March 6, 2020
Re: Docket No. FNS-2019-0007; Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs
On behalf of the Union of Concerned Scientists (UCS), I submit this comment to the US Department of Agriculture (USDA) Food and Nutrition Service to express strong opposition to the dismantling of evidence-based school nutrition standards via the policy changes contained in the proposed rule “Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs.”
UCS is a science-based nonprofit working for a healthy environment and a safer world. Our organization combines independent scientific research and citizen action to develop innovative, practical solutions to some of the nation’s most pressing challenges and secure responsible changes in government policy, corporate practices, and consumer choices.
The nutrition standards established under the bipartisan Healthy, Hunger-Free Kids Act of 2010 (HHFKA) were developed in alignment with federal dietary guidelines to support healthy eating behaviors and reduce long-term risk of chronic disease among our nation’s children. The current state of US population health demands that we take federal dietary guidance seriously: nearly one in five youth and two in five adults experience obesity, with associated medical costs estimated at 21 percent of all national health expenditures., Meanwhile, diet-related diseases such as cardiovascular disease and type 2 diabetes are among the leading causes of US morbidity and mortality, with an estimated 18 percent of deaths nationwide attributable to dietary factors.,
Children consume as much as half of their daily calories at school; children from food-insecurhouseholds, in particular, get a larger proportion of their daily food and nutrition intake from school meals than other children., With 30 million students eating school meals and snacks each day, schools have a tremendous opportunity to support healthy behaviors and reduce long-term chronic disease risk—making evidence-based school nutrition standards one of the best public health tools at our disposal., Studies suggest that the HHFKA is one of the most effective strategies for reducing childhood obesity, and it is estimated that the policy will prevent more than 2 million cases over the span of ten years. Researchers at the Harvard T.H. Chan School of Public Health have named the HHFKA “one of the most important national obesity prevention policy achievements in recent decades.”
Given the critical need to improve child nutrition and the demonstrated effectiveness of the HHFKA in doing so, UCS is dismayed by the changes to evidence-based nutrition standards contained in the proposed rule and urges the USDA to abandon them. The changes contained in this rule—in combination with other regulatory changes the USDA has recently implemented—would erode evidence-based nutrition standards to such a degree that the potential public health benefits associated with nutritious school meals could be deeply diminished.
Our opposition to the rule is grounded in the following:
The proposed rule could substantially reduce the healthfulness of school meals, putting the health of millions of children at risk. The changes contained in the proposed rule contradict the best available nutritional science and the 2015-2020 Dietary Guidelines for Americans, which explicitly recommend a healthy eating pattern that includes more fruits, whole grains, and a variety of vegetables, and limits sodium.
According to the USDA’s own research, the nutrition standards implemented under the HHFKA increased the healthfulness of school breakfast (as measured by the Healthy Eating Index) by 44 percent, an improvement attributed primarily to increased servings of fruits and whole grains. However, the changes outlined in the proposed rule could result in one less cup of fruit and up to two fewer servings (ounce equivalents) of whole grains eaten at breakfast each day, threatening the documented improvements in the healthfulness of meals served at breakfast. Furthermore, the proposed rule would permit schools to serve meat (one- to two-ounce equivalents) in place of grains at breakfast, increasing the likelihood that children are regularly consuming processed meat such as sausage and bacon. Research shows that increased consumption of processed meat is associated with greater risk of colorectal cancer; as a result, leading research institutions such as the American Institute for Cancer Research and the World Health Organization have recommended consuming little to no processed meat.,
Research from the USDA has also demonstrated that the healthfulness of school lunches increased by 41 percent following the implementation of the HHFKA nutrition standards, with the largest gains attributed to increases in whole grains and greens and beans.10 The USDA’s 2018 rule, “Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium requirements,” which was made effective in February 2019, has already diminished the healthfulness of school meals by halving the amount of grain-based products that must be whole grain-rich in school breakfast and lunches. Additionally, the new rule proposes to strike the current requirement that entrées that include grains and are sold à la carte must be whole grain-rich or have a whole grain as the first ingredient.
Further, the new proposed rule allows legumes to count as both a meat alternate and a vegetable serving from the legume subgroup, enabling schools to elect to serve any variety of vegetables—including starchy, low-nutrient varieties such as potatoes and corn—in place of legumes to help meet minimum weekly vegetable requirements. The cumulative impact of proposed changes to the weekly requirements for vegetable subgroups, including flexibilities for crediting legumes and reductions in required vegetable servings from red/orange and “other” vegetable subgroups, would result in schools having the ability to serve as many as three and a half cups of potatoes to students per week at lunchtime alone. If potatoes were also substituted for fruit at breakfast, which would be permissible under the proposed rule, children could be consuming as much as eight and a half cups of potatoes at school each week.
In addition to eroding the standards that have improved the healthfulness of school meals, the proposed rule also contains changes that would make it far easier for students to purchase items such as pizza, hamburgers, and French fries that are neither subject to meal pattern requirements nor Smart Snacks nutrition standards developed for foods sold à la carte. This effectively undermines the intent of nutrition standards altogether, as it means that children could choose to purchase an entrée every day of the week that is not subject to nutritional requirements.
The proposed rule could exacerbate diet- and health-related inequities among children nationwide. The vast majority of the children participating in school meal programs are from low-income households. In recent years, 74 percent of lunches and 85 percent of breakfasts were provided either for free or at reduced cost to students based on household income level. One study found that a group of primarily low-income students obtained 47 percent of their daily calories at school, including 58 percent of fruit intake, 41 percent of vegetable intake, 52 percent of grain intake, and 70 of total milk intake. Though nutritious meals confer benefits to all participating children, the nutritional quality of foods provided at school is particularly important for children from low-income households. Research has consistently shown that low-income households do not achieve parity with higher-income households when it comes to diet quality, even after adjusting for education and other factors., In addition to reducing the nutritional quality of school meals, the proposed rule introduces a regulatory change that would allow schools to bypass current requirements to offer free potable drinking water to all children by offering calorie-free, naturally flavored, noncarbonated water instead. The proposed rule is unclear as to whether the naturally flavored water option must be offered free of charge or if it could be sold to children; if the latter, this regulatory change is discriminatory in nature, as students without the financial means to purchase naturally flavored water could lack access to water of any kind.
The relationship between poverty and race in the United States means that children of color are also more likely to participate in school meal programs. Recent research has shown that, due in part to decades of racist policies and practices promoting school segregation, Black children are more than twice as likely than white children to attend high-poverty schools where more than half of the student population is eligible for free or reduced-price lunch. Meanwhile, it is estimated that Hispanic students represent about one-quarter of all children participating in the school lunch program, and make up nearly one-third of children who receive free and reduced-price lunches. Regardless of income level, many children of color face unique challenges to eating healthfully as a result of unhealthy food marketing, which is itself a contributor to poor diets and diet-related disease. Findings from the University of Connecticut’s Rudd Center for Food Policy and Obesity have shown that restaurants and food and beverage companies disproportionately market their least nutritious products, including fast food, candy, sugary drinks, and snacks, to Black and Hispanic youth.
Research has found that the nutrition standards implemented by the HHFKA were effective in reducing numerous disparities related to the nutritional quality of school meals. For example, a 2015 study showed that prior to the introduction of the new standards, students in predominantly white schools were more likely to have healthier options, including fruits, vegetables, and whole grains, and less likely to have sugar-sweetened beverages available on a daily basis; after the introduction of the new standards, these disparities were largely eliminated. Rolling back science-based regulations may erase these gains entirely, exacerbating existing inequities and health disparities that disproportionately affect low-income populations and communities of color and putting many children on a path to poorer health.
Evidence contradicts the USDA’s stated justifications for the proposed rule. According to the USDA, the rationale for the proposed rule is to provide customer-focused flexibilities to help state and local operators of school nutrition programs overcome operational challenges. These justifications are largely unsupported by evidence, including the USDA’s own findings.
As early as 2016, the USDA reported that more than 99 percent of schools were already meeting the HHFKA nutrition standards. USDA research also showed that the adoption of more stringent nutrition standards since 2012 was not associated with increased food waste, and that healthier school meals were actually associated with increased participation in school meal programs.10 Even the justifications for simplifying current requirements for vegetable varieties, including weekly minimum amounts of red and orange vegetables, are unfounded: research shows that between 92 and 95 percent of school lunch menus were already satisfying vegetable variety requirements.
In summary, UCS finds that the aforementioned changes to nutrition standards contained within the proposed rule could compromise the health of children nationwide, with disproportionate impacts for children who already face greater risk of health disparities. While we support efforts to reduce food waste, improve the efficiency of school food service, and reduce administrative burdens for school food service providers, we strongly urge the department to identify solutions that do not detract from the nutritional quality of school food menus and student diets.
Thank you for your careful consideration of the comments provided by UCS and leading public health and nutrition experts in response to the proposed rule “Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs,” Rather than dismantling effective, evidence-based bipartisan policy, we urge the USDA to continue providing the critical support schools need to implement science-based standards that offer children nationwide the best opportunity for a healthy future.
Sarah Reinhardt, RD, MPH
Lead Food Systems and Health Analyst
Food & Environment Program
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