March 14, 2016
The Honorable Thomas J. Vilsack
Secretary of Agriculture
1400 Independence Avenue, SW
Washington, DC 20250
Dear Secretary Vilsack,
Re: Child Nutrition Program Operations Study II (CN-OPS II) (OMB 0584-NEW)
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the United States Department of Agriculture's (USDA) Food and Nutrition Service (FNS) on the proposed information collection, Child Nutrition Program Operations Study II (CN-OPS II or the "Study") released February 11, 2016. Representing more than 100,000 registered dietitian nutritionists (RDNs),1 dietetic technicians, registered (DTRs), and advanced-degree nutritionist researchers, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation's health through food and nutrition across the lifecycle. Every day we work with Americans in all walks of life—from birth through old age—including many members' work providing and designing effective child nutrition programs and nutrition education initiatives.
The Academy supports the purpose of the Study to collect and analyze data on policy, administrative, and operational issues for the Child Nutrition Programs, provide input for new legislation, and provide pertinent training and technical assistance. School nutrition professionals, including many RDNs, struggle with a "trilemma" of problems: meeting the nutritional requirements of the student; minimizing program costs (including maintaining outdated facilities); and maximizing student acceptability and participation. We look forward to working with FNS and other stakeholders to improve the financial health of Child Nutrition Programs, identify strategies to improve program flexibility, and ensure high levels of participation.
The timing of the Study is particularly appropriate, given the significant improvements to Child Nutrition Programs mandated as part of the Healthy Hunger-Free Kids Act of 2010.2 It is the position of the Academy of Nutrition and Dietetics that children and adolescents should have access to an adequate supply of healthful and safe foods that promote optimal physical, cognitive, and social growth and development.3 Nutrition assistance programs, such as school food service programs, the Child and Adult Care Food Program, WIC, and SNAP, and associated nutrition education initiatives, play a vital role in meeting this critical need.
Coordinated Nutrition Education
Coordinated nutrition education programs play an important role in improving the health status of students and are fundamental to effective Child Nutrition Programs. They have been shown to have positive impacts on educational outcomes and health risk behaviors. The Centers for Disease Control and Prevention's Coordinated School Health Model describes various health components necessary across all aspects of the school environment.4 Nutrition services are an integral component of this coordinated model, designed to help prevent obesity and improve the health status of children in the United States. Collaboration with the community and the school responsible for each of these components is required for success. Coordinated at the national level, administered at the state level, and implemented at the local level, a well-funded national nutrition education and promotion program, focusing on comprehensive school nutrition services, would provide needed infrastructure and leverage resources among other nutrition-related federal programs. Partnering with the education community, RDs and other food and nutrition practitioners stand ready to develop national nutrition education standards, along with innovative, cost-effective strategies for strengthening the nutrition education provisions of local school wellness policies.
Effective nutrition education and promotion must: (1) focus on specific behaviors; (2) address the interests and motivations of the intended audience; (3) allow enough time and intensity to achieve positive results; (4) deliver sequential curricula in an organized manner; (5) involve several aspects of the child's environment, at home, at school, and in the community; and (6) provide professional staff development. Multiple approaches including changes to both the environment and policies, planned initiatives and the curriculum, and social marketing are crucial for success. Fifty hours of nutrition education in the classroom that is based on sequential instruction and skill-building, and that incorporates family involvement, is needed to impact behavior change, yet too few students receive the recommended 50 hours.5,6 In fact, a 2000 US Department of Education report determined the mean number of hours spent in a school year on nutrition education by elementary school teachers was only 13.7
Research shows that innovative, hands-on, and behaviorally-focused teaching strategies enhance healthful eating.8 An evidence-based, collaborative approach requires a well-funded and comprehensive nutrition education and promotion platform.9 Dedicated funds are needed to support the inclusion of nutrition education to school curricula to meet wellness policy goals, and successful inclusion can be measured by the presence of multiple indicators:
- A variety of delivery points and communication tools are used to deliver consistent nutrition messages;
- Special events and promotions are routinely implemented in the school cafeteria;
- School gardens and other local food production are integrated into the curricula;
- Nutrition information about food items and menus are readily available;
- School nutrition staff, administrators, and teachers participate in staff development to learn more about scientifically factual nutrition;
- Nutrition is integrated into all subject areas, including language arts, science, and mathematics;
- Nutrition curricula are sequential, comprehensive, and adequate to result in behavioral changes; Nutrition education messages target specific behaviors, using multiple components, such as policy change and social marketing;
- Nutrition education strategies are innovative and appeal to students' interests and motivations;
- School cafeteria is used as a learning laboratory where students can apply nutrition content learned in the classroom; and
- School nutrition personnel are actively involved in nutrition education at the school level.
Given the unfortunate lack of sufficient funding for nutrition education in and out of schools, the Academy recommends that FNS encourage state child nutrition agencies to work collaboratively with their respective state SNAP-ED agencies and other community partners to coordinate nutrition education efforts for schools as part of their Nutrition Education and Obesity Prevention Grant Programs.
The Academy sincerely appreciates the ongoing opportunity to offer comments to FNS on shaping and implementing Child Nutrition Programs. Please contact either Jeanne Blankenship by telephone at 202-775-8277 ext. 1730 or by email at firstname.lastname@example.org or Pepin Tuma by telephone at 202-775-8277 ext. 6001 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Government and Regulatory Affairs
Academy of Nutrition and Dietetics
1 The Academy recently 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 Healthy, Hunger-Free Kids Act of 2010, 42 U.S.C. § 1751 et seq. (2010).
3 Stang J, Bayerl CT. Position of the American Dietetic Association: child and adolescent nutrition assistance programs. J Am Diet Assoc. 2010;110(5):791-99.
4 Centers for Disease Control and Prevention. Healthy Youth!: Coordinated School Health Program. Last modified August 19, 2015. Accessed March 14, 2016.
5 Connell D, Turner R, Mason E. Summary of findings of the school health education evaluation: Health promotion effectiveness, implementation, and costs. J Sch Health. 1985; 55:316-321.
6 Celebuski C, Farris E. Nutrition education in public elementary school classrooms, K-5. Washington, DC: US Department of Education, Office of Educational Research and Improvement; 2000. NCES 2000-040.
8 Institute of Medicine. Nutrition Standards for Foods in Schools: Leading the Way toward Healthier Youth. Washington, DC: National Academies Press; 2007:16, 106.
9 O'Toole T, Anderson S, Miller C, Gutherie J. Nutrition services and foods and beverages available at school: Results from the School Health Policies and Programs Study 2006. J School Health. 2007;77:500-521.