September 23, 2019
Jeffrey M. Zirger
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE
Atlanta, Georgia 30329
RE: DP18-1801 Health Schools Program Study (CDC-2019-0060)
Dear Mr. Zirger:
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Centers for Disease Control and Prevention related to its request for feedback on the DP18-1801 Healthy Schools Program Study (CDC-2019-0060), originally published in the Federal Register on July 25, 2019 (84 FR 35863). Representing more than 107,000 registered dietitian nutritionists (RDNs),1 nutrition and dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States. We are committed to accelerating improvements in the nation’s health and well-being through food and nutrition.
The Academy supports data collection efforts to study and share best practices from the DP18-1801 Healthy Schools Program grantees and recommends that the study questions include capturing best practices around nutrition education, school meal participation promotion and adequate seat time for meal consumption.
Opportunities to enhance the quality, utility, and clarity of collected information
Nutrition education continues to be important to schools and to students, but, with competing educational priorities, the unfunded requirements of the local wellness policy, and the consistent underfunding of current national nutrition education and promotion efforts, nutrition education has not been given adequate prioritization in schools. Given the aim of the Healthy Schools Program to support efforts to improve student dietary intake, it is important to understand the role of nutrition education in the success of grantees. Specifically the Academy recommends capturing data on what types of interventions were implemented, who delivered the program, and what other funding sources or programs complemented the Healthy Schools Program.
Decrease in Paid Level Student Meal Participation
The National School Lunch Program provided low-cost or free lunches to 29.7 million children daily in 2018; participation has declined in six of the last seven years.2 The biggest decline has been seen in the paid student category. According to the School Nutrition and Meal Cost Study-I, in SY 2014–2015, a 10 cent increase in the price of a paid lunch was associated with a decline of 0.7 percentage points in the rate of paid meal participation in the NSLP.3 The Academy is concerned that the Paid Lunch Equity provision from Healthy Hunger Free Kids Act is out-pricing paid students from the program and is limiting the reach and impact of the newly improved school nutrition environment for all students. The Academy encourages tracking the school meal participation rates in the grantee schools and analyze what interventions were successful in getting students, of all paid categories, to eat healthy school meals.
Adequate Seat Time for Meal Consumption
The Meal Cost Study from U.S. Department of Agriculture4 suggests that food waste is still a concern for the school meal program. The CDCP suggests that children need at least 10 minutes to eat breakfast and 20 minutes to eat lunch. The Academy recommends capturing data about successful efforts to provide students with the opportunity for adequate seat time to consume healthful meals.
The Academy appreciates the opportunity to submit comments to the CDCP related to its request for feedback on the DP18-1801 Healthy Schools Program Study. The Academy urges CDCP to consider making changes to the survey instrument and methods to improve the clarity and utility of the survey and capture information about current topics where limited data is currently available. Please contact either Jeanne Blankenship at 312/899-1730 or by email at email@example.com or Liz Campbell at 202/775-8277, ext. 6021 or by email at firstname.lastname@example.org with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Liz Campbell, MA, RDN
Legislative & Government Affairs
Academy of Nutrition and Dietetics
1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation’s food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
2 USDA. National School Lunch Program. Accessed September 22, 2019.
3 School Nutrition and Meal Cost Study. Accessed September 22, 2019.