December 2, 2013
Senior Program Analyst
Food and Nutrition Service, USDA
3101 Park Center Drive, Room 1004
Alexandria, VA 22302
Re: FR Doc No: 2013-24142 (Agency Information Collection Activities: Proposed Collection; Comment Request—School Nutrition and Meal Cost Study)
Dear Mr. Endahl:
The Academy of Nutrition and Dietetics is pleased to comment on the proposed information collection from the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) related to its School Nutrition and Meal Cost Study published in the Federal Register. The Academy is the world’s largest organization of food and nutrition professionals, with more than 75,000 members comprised of registered dietitian nutritionists (RDNs),1 registered dietitians (RDs), dietetic technicians, registered (DTRs), and advanced-degree nutritionists. Every day we work with Americans in all walks of life—from prenatal care through old age—providing nutrition care and conducting nutrition research. We are committed to improving the nation’s health and meeting nutrition needs through the lifecycle and play a major role in food safety education and research. Already, Academy members have helped bring real change to school meals across America, with many employed in child nutrition programs at the local, state, and national levels as school nutrition program directors, assistant directors, and program managers; as researchers and educators; as suppliers of products and services to school foodservice operations; and as consultants in school nutrition and wellness.
Academy Supports School Nutrition and Meal Cost Study
The Academy supports FNS’s efforts to assess the effects of changes to the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) stemming largely from implementation of the transformative Healthy, Hunger-Free Kids Act (HHFKA) of 2010. The proposed information collection is necessary for the proper performance of FNS’s functions in that it provides FNS with crucial information “to assess the effects of the new nutrition standards on foodservice operations, the nutrient content of school meals as offered and served, meal costs and revenues, and student consumption of school meals and dietary intake.” We look forward to ongoing comprehensive reviews of these changes to the NSLP and SBP and are hopeful that FNS and state agencies continue working together to ensure and monitor ongoing compliance with heightened, cost-appropriate nutrition standards.
Enhancing the Quality, Utility, and Clarity of the Information to Be Collected
The Academy notes that the information collection seeks data from a generally appropriate group of individuals with significant knowledge of and experience with the new meal standards. However, we encourage FNS to additionally seek data from entities representing engaged stakeholders with expertise in school meal nutrition standards, whether School Wellness Committees, or as Parent Teacher Associations (PTAs) or Parent Teacher Organizations (PTOs). These groups may have significant influence on the school food environment through their role in communicating and supporting new school meal standards, through facilitating feedback to school nutrition professionals, school day fundraising practices, and assisting with successful implementation in some cases. FNS should consider an assessment of the impact of how varying various stakeholder involvement has influenced the roll-out of and satisfaction with the HHFKA’s new school meal standards. In addition, we encourage FNS to specifically assess any impact of various school wellness policies on student consumption, dietary intake, and satisfaction with the NSLP and SBP.
The proposed study methodology appears generally sound and the described modes of data collection appear similar to USDA’s School Nutrition Dietary Assessment, regarded as the best practice school nutrition data collection. The Academy suggests that FNS consider the added value of increasing the amount of data collected and the number of respondents selected in order to make a more accurate nationwide conclusion of the effects of the HHFKA. However, we remain concerned about the number of variables and lack of specified baseline data that might preclude FNS from reaching an accurate nationwide conclusion, and urge FNS to share its methodology with stakeholders to allay these concerns. The Academy certainly defers to statisticians involved in this important project, however, respecting that they must conduct the study within given budget parameters.
The Academy is hopeful that FNS will structure the School Nutrition and Meal Cost Study to reduce the likelihood of error in collections from the specified sources of information, specifically self-assessments and plate waste studies. We encourage FNS to confirm prior to initiating the study that the interviews are consistently structured and sufficiently concise to ensure a dependable result. In addition, we suggest that meal cost estimates could be more accurately captured by ensuring that each respondent completes the same revenue/expenditure figures over the same timeframe. The Academy also notes that the type of meal production may be a factor (i.e., is the SFA comprised of multiple schools, do types of preparation systems differ—such as central kitchens as opposed to onsite preparation), as these variances may complicate the process of obtaining exact comparative costs.
Further, we urge FNS to provide local education agencies and stakeholders with specific instructions sufficient to ensure data is reported consistently with minimal opportunities for subjective assessment, such that each respondent assesses each component similarly by using comparatively consistent criteria. Studies of food waste in particular should endeavor to avoid inconsistencies and error resulting from the differing observational processes of various stakeholders. The use of digital photography can help eliminate subjective assessments, and “settings, people, processes, activities, interactions, and meaning of phenomena from the perspective of the participants” should be described.2 We also note that subjectivity may be reduced when observers record field notes at intermittent times.
Noting that it often takes children multiple exposures to accept new foods, the Academy also encourages FNS to identify the ‘early adopters’ of the various new nutritional standards and discern the degree to which plate waste differs among schools and students that have had longer to adapt to the changes. Schools meeting USDA’s HealthierUS School Challenge may be appropriate examples of early adopters, as they are recognized for their success in meeting many of the new meal standards. The Academy encourages FNS to consider whether observational assessments of the degree of plate waste in the study could possibly be confirmed by comparison to production and purchase records that may evidence a trend of consumption of salad bar elements, whole grain items, and other items to be encouraged consistent with the new school nutrition standards.
Lastly, to the extent that it is germane to this information collection, we encourage FNS to take special note during the study of any changes in practices or available foods for developmentally disabled students, particularly those receiving meals with texture modifications or calorie content different from the national meal standards. FNS should note whether foods prepared for special needs children are (1) prepared in a sanitary fashion by nutrition professionals consistent with state and federal law and (2) meet the heightened HHFKA nutrition standards or other, different standards as required.
Offering the Academy of Nutrition and Dietetics’ Continued Assistance
School nutrition professionals, including many registered dietitian nutritionists, 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. The Academy shares FNS’s commitment “that more children from all income levels adopt the kind of healthful eating habits and lifestyles that will enable them to live longer, more productive lives,” and hopes that FNS will utilize the collected information to help effectuate this purpose.
Our members can continue to provide expertise in developing and promoting materials that encourage children to accept healthy options; strategies, such as behavioral economics, can foster healthier meal selection by students and increase participation in and promotion of the meal programs. The Academy is particularly supportive of nutrition education and school wellness programs that educate students on agriculture and food systems and provide nutrition education through integrative, hands-on, and collaborative learning opportunities. The Academy remains committed to school nutrition programs that provide safe foods managed by trained and educated school nutrition professionals such as RDNs that successfully combine sound financial practices with the provision of healthy, nutritious meals.
The Academy appreciates the opportunity to comment on the proposed information collection and offer the Academy’s and our members’ expertise as you develop methodologies and continue implementation and oversight of the new school meal nutrition standards. Please contact either Jeanne Blankenship at 202/775-8277, ext. 1730 or by email at firstname.lastname@example.org or Pepin Tuma 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
Vice President, Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Director, 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 Harris JE, Gleason PM, Sheean PM, Boushey C, Beto JA, Bruemmer B. An introduction to qualitative research for food and nutrition professionals. J Am Diet Assoc. 2009;109(1):80--90.