May 28, 2019
Dr. Mark Schneider, Director
Institute of Education Sciences
U.S. Department of Education
400 Maryland Ave SW; Room 4109
Potomac Center Plaza
Washington, DC 20202
Re: Docket Number ED-2019-IES-0017; Proposed Priorities for the Institute of Education Sciences
Dear Dr. Schneider:
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit these comments to the Institute of Education Sciences, U.S. Department of Education related to its March 28, 2019 request for information "Proposed Priorities for the Institute of Education Sciences." Representing more than 104,000 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 world and is committed to a vision of the world where all people thrive through the transformative power of food and nutrition and related support systems. Every day we work with Americans in all walks of life — from prenatal care through end of life care — providing a variety of nutrition care services, including school food service management and nutrition education for children and adolescents.
The Academy strongly supports the IES initiatives for "conducting surveys and evaluations and gathering statistics to improve the academic achievement and the access to high-quality education of all learners from early childhood to adulthood." Because nutrition education is a key determinant of student health, academic achievement, social interactions and behaviors, and thus overall success in career development and economic participation, we recommend priorities include a thorough assessment of nutrition education in all public schools.
A. The Current State of the Availability of Nutrition Education
Increased pressure on teachers, staff, and school districts to ensure their students meet or exceed accepted benchmarks on standardized tests may place the education focus on core curriculum subjects, leaving less time for nutrition education and physical activity.2 Although school officials have generally not yet prioritized nutrition education and physical education, the Academy encourages it, as the benefits are substantial and diverse.3
Some uncertainty remains in guidelines for duration of nutrition education, but it is believed that a minimum of 50 hours per school year (or 15 minutes daily) is required to produce a meaningful effect on student behavior.4,5 Current estimates indicate students are receiving significantly less than this, about 4 - 6 hours per year, or 1 - 2 minutes daily.6 This situation has substantial adverse implications for several IES priorities, specifically:
- readiness for school
- academic achievement
- graduation rates
- school climate
- mental health
- behaviors and social skills
- career and life success
B. Nutrition Education is Essential to Health, Education and Lifelong Success
Nutrition education is defined as all of the educational activities that engage students—not only through direct classroom education but also through other venues throughout the school campus during the school day—that are designed to motivate students and facilitate adoption of healthful food choices accompanied by a supportive school environment.7 Nutrition education is a required component of school wellness policies, which are defined as "written document[s] of official policies that guide a local educational agency (LEA) or school district's efforts to establish a school environment that promotes students' health, well-being, and ability to learn by supporting healthy eating and physical activity."8 The Child Nutrition and WIC Reauthorization Act of 2004 introduced, and the Healthy, Hunger-Free Kids Act of 2010 reinforced, school wellness policies, requiring each LEA participating in the National School Lunch Program (NSLP) or the School Breakfast Program (SBP) to establish such a policy. When wellness policies emphasize a multi-faceted approach, each additional component decreased obesity prevalence by about 3%.9 Thus, wellness policies are a primary tool to promote student wellness and prevent and treat early onset of chronic conditions, such as obesity, and its sequelae.
Unfortunately, many school wellness policies may be "weak, fragmented and do not necessarily require schools to take action." While 52% of policies in one survey did require skill-based nutrition education, less than 1% specified a minimum number of courses or contact hours.10>
It is the position of the Academy that well-planned nutrition education content throughout the school-age years is critical to enhance health, improve nutritional adequacy, and increase academic success.11 For optimal impact, nutrition education should be planned in conjunction with improved school meals, availability of healthful competitive foods throughout school environments, effective wellness policies, other food- and nutrition-related activities in the school, and reinforcement at home and community.12 Nutrition education can take many forms beyond traditional teaching methods, and may include school gardens, teaching math with fruit, the science of vitamins and minerals, and social studies in food marketing. It's also important to add interactive, experiential skills education to ensure students can be prepared to shop, cook, and make healthy choices, and thus create a healthier society.13,14 Unfortunately, there are no standards or guidelines for nutrition education content or format, which can create discrepancies and gaps in knowledge for school aged children. In fact, only 35% of school districts require some sort of nutrition education at every grade level.15
1. Impact on Health Outcomes
Almost 20% of school age children in the U.S. have obesity,16 which is associated with increased risks of adult obesity, other chronic diseases, and increased health care costs.17 Notably, the majority of children are not following recommended dietary patterns and are specifically not consuming the recommended amounts of fruits and vegetables, but about 40% of their daily calorie intake derives from empty calories, with much of that contributed by various sugar-sweetened beverages and fruit juice, dairy and grain desserts, and pizza.<18
Strong wellness policies have been shown to have a positive impact on children's health, improving healthy eating in school meals as competitive foods, as well as a decreased risk of childhood obesity.19 Particularly, nutrition education utilizing a whole school approach (i.e., integration of curriculum, environment, school culture and community involvement) may be essential to optimizing improvements in fruit and vegetable intake, high-fiber foods, water, and healthier snacks.20,21 Similar approaches may also decrease intake of low-nutrient dense foods, high fat foods, and sugar-sweetened beverages, while helping to maintain healthy body weight over the long term.22,23
Nutrition education is also likely to produce other positive benefits that address other health-related challenges, including undernutrition, iron deficiency anemia and dental caries.24 Nutrition education may also positively affect mental health concerns, such as risk of eating disorders, body image dissatisfaction, discrimination, and weight-related bullying.25 At the same time, children who suffer from obesity are more likely to also experience bullying, discrimination, feelings of isolation and depression.26
2. Impact on Education Outcomes
Proper nutrition education can improve academic performance, behavior and achievement in school.27 At the same time, poor nutrition and physical inactivity is correlated with "behavioral problems, short-term thinking, lack of motivation, disengagement from learning, and absenteeism."28 These concerns increase risks of poor achievement in established measures of performance, including grades, standardized test scores, grade level retention, and dropping out.29
Academic performance is also related to food insecurity, which may even coexist with obesity.30 Nutrition education is one important tool to mitigate food insecurity,31 which is associated with a virtual laundry list of potential negative consequences for a school-aged child's cognitive development and academic success. This includes:
- impaired academic performance
- increased hyperactivity and inattention
- missing school
- less adaptive approaches to learning
- grade repetition
- use of special education services
- suspension from school32
3. Impact on Society
Nutrition education contributes to improved health and academic performance in children and pediatric success frequently translates to adult success; thus, improved workforce productivity, and decreased employee absenteeism are the natural result.33 Add in the savings in health care costs associated with nutrition education: for obesity alone, the savings is estimated at $900 - $12,000 for each additional life-year saved.34 Ultimately, nutrition education improves the national economy by increasing profitability and competitiveness in a global marketplace.
Nutrition education's role in reducing obesity could also improve mission readiness for our national defense. The CDC estimates that 25% of young people are unable to join the military due to excess weight.35 Among active duty service members, obesity is associated with 33% increased risk of musculoskeletal injuries, rendering many members medically unable to deploy. The Department of Defense is also spending $1.5 billion for obesity-related health care costs and another $100 million due to lost workdays. Such impacts are directly affecting recruitment, military readiness, and thus, national security, placing our nation at increased risk.36
The success of efforts to improve our economy, eliminate barriers to individuals entering the economy, and improve military readiness may be limited unless education outcomes improve. Education outcomes may, in turn, be limited, unless children's nutrition status improves. Since improvements in nutrition status may be predicated upon successful integration of effective nutrition education and related wellness policies, effective nutrition education is a key component of a strong national economy and effective national security.
LEAs should develop meaningful, whole school wellness policies that promote health and establish specific minimum standards for nutrition education, including 50 hours of classroom instruction per academic year. Schools should not only motivate and teach the knowledge and skills for children to make healthful choices, but also should provide an environment fostering healthful eating. Implementation of strong policies ensures that the overall food-and-beverage environment, including competitive foods, supports desired health, education and societal outcomes.
The Academy recommends that IES support quantitative and qualitative research documenting school nutrition program availability, content and effectiveness. This includes research of program design, implementation, and evaluation of innovative programs such as school gardens, salad bars, culinary education, healthful food promotion, and farm-to-school programs, as well initiatives to ensure program continuity. Research is also needed on how best to scale up existing effective programs. This research agenda will contribute to improved health of the nation's children, academic success and economic and national security. The Academy also supports adequate funding, professional development, curricula and resources to help ensure that students preschool-12 receive effective, evidence-based nutrition education.
The Academy notes the federal government's past efforts to improve and standardize nutrition education and address related concerns in conjunction with passage of the Healthy, Hunger-Free Kids Act of 2010. In 2013, the National Academies of Sciences convened a workshop to discuss these topics and their implications for the nation's health and economy.37 In the 114th Congress, the Nutrition Education Act (HR 3800) was introduced, which would have required a 50-hour minimum for annual nutrition education.38 The bill, which would have applied to all LEAs participating in NSLP or SBP, unfortunately has yet to be passed. IES should consider collaborating with other partners in advance of a national campaign to reintroduce The Nutrition Education Act.
The Academy appreciates the opportunity to comment on the "Proposed Priorities for the Institute of Education Sciences" docket. Please contact either Jeanne Blankenship at 312/899-1730 or by email at email@example.com or Mark Rifkin at 202/775-8277, ext. 6011 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
Mark E. Rifkin, MS, RD, LDN
Consumer Protection and Regulation
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 IOM (Institute of Medicine). 2012. Accelerating Progress in Obesity Prevention: Solving the Weight of the Nation. Washington, DC: The National Academies Press. pp. 329-378. Accessed May, 2019.
3 IOM, Accelerating Progress in Obesity Prevention.
5Stage VC, et al. Exploring the Associations Among Nutrition, Science, and Mathematics Knowledge for an Integrative, Food-Based Curriculum. J Sch Health. 2018 Jan;88(1):15-22.
6IOM, Accelerating Progress in Obesity Prevention.
7Hayes D, Contento IR, Weekly C. Position of the Academy of Nutrition and Dietetics, Society for Nutrition Education and Behavior, and School Nutrition Association: Comprehensive Nutrition Programs and Services in Schools. Journal of the Academy of Nutrition and Dietetics. 2018;118(5):913-919.
8"Local School Wellness Policy." Food and Nutrition Service, USDA. Accessed May, 2019
9Hayes, Contento and Weekly.
10 Beckwith S, Cooper M, Goesch H, MacKinnon G. "Nutrition Education in America's Schools: A Policy Brief." The Association of State Public Health Nutritionists. Accessed May, 2019.
11 Hayes, Contento and Weekly.
14 IOM, Accelerating Progress in Obesity Prevention.
15 University of Wisconsin Population Health Institute, County Health Rankings & Roadmaps "School-based nutrition education programs." Accessed May, 2019.
16 CDC Healthy Schools: Childhood Obesity Facts. Accessed May, 2019.
17 Cheung PC, et al. Childhood Obesity Incidence in the United States: A Systematic Review. Child Obes. 2016 Feb;12(1):1-11.
18 CDC Healthy Schools: Childhood Nutrition Facts. Accessed May, 2019.
19 Hayes, Contento and Weekly.
20 Howerton MW, et al. School-based nutrition programs produced a moderate increase in fruit and vegetable consumption: meta and pooling analyses from 7 studies. J Nutr Educ Behav. 2007 Jul-Aug; 39(4):186-96.
21 County Health Rankings & Roadmaps. "School-based nutrition education programs."
22 Wang D, Stewart D. The implementation and effectiveness of school-based nutrition promotion programmes using a health-promoting schools approach: a systematic review. Public Health Nutrition. 2012;16(6):1082-1100.
23 Ickovics JR, et al. Implementing School-Based Policies to Prevent Obesity: Cluster Randomized Trial. Am J Prev Med. 2019 Jan;56(1):e1-e11.
24Beckwith S, Cooper M, Goesch H, and MacKinnon G.
26 Food and Nutrition Board; Board on Children, Youth, and Families; Institute of Medicine. Nutrition Education in the K-12 Curriculum: The Role of National Standards: Workshop Summary. Washington (DC): National Academies Press (US); 2013 Aug 21. Accessed May, 2019.
27 Beckwith S, Cooper M, Goesch H, and MacKinnon G.
28 Nutrition Education in the K-12 Curriculum.
30 Larson, Nicole I. et al. Food Insecurity and Weight Status Among U.S. Children and Families. Am J Prev Med; 40(2):166-173.
31 Kamimura A, et al. Food Insecurity Associated with Self-Efficacy and Acculturation. Popul Health Manag. 2017 Feb;20(1):66-73.
32 Shankar P, Chung R, Frank DA. Association of Food Insecurity with Children's Behavioral, Emotional, and Academic Outcomes: A Systematic Review. J Dev Behav Pediatr. 2017 Feb/Mar;38(2):135-150.
33 Beckwith S, Cooper M, Goesch H, and MacKinnon G.
34 Hard A, Uno C, Koch, PA. "The Importance of Nutrition Education in the 2015 Child Nutrition Reauthorization." Laurie M. Tisch Center for Food, Education & Policy. Accessed May, 2019.
35 Unfit to Serve: Obesity Is Impacting National Security. Centers for Disease Control and Prevention. Accessed May, 2019.
37 Nutrition Education in the K-12 Curriculum.
38 H.R. 3800 "The Nutrition Education Act."