December 5, 2016
Devin Wallace-Williams, Ph.D.
Social Science Research Analyst
Office of Policy Support
Food and Nutrition Service, USDA
3101 Park Center Drive, VA 22302
Re: Proposed Collection; Comment Request-Child Nutrition Program Operations Study II (CN-OPS-II)
Dear Dr. Wallace,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Nutrition Service (FNS) of the United States Department of Agriculture (USDA) regarding the information collection on the "Child Nutrition Program Operations Study II (CN-OPS-II)." Representing over 100,000 registered dietitian nutritionists (RDNs),1 nutrition dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, 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 and work to ensure that all Americans have access to a healthy, safe food supply by leading efforts to reduce food deserts and food swamps and by delivering effective nutrition education programs.
Because the Academy supports initiatives and programs that provide for improved levels of nutrition among low-income households, we support the proposed collection of information as necessary for the proper performance of the functions of the agency, particularly given the practical utility resulting from the CN-OPS-II.
A. Utility and Necessity of the Proposed Information Collection
CN-OPS-II is designed to "collect timely data on policies, administrative, and operational issues on the Child Nutrition Programs (CNP). The ultimate goal is to analyze these data and to provide input for new legislation on Child Nutrition Programs, as well as to provide pertinent technical assistance and training to program implementation staff." As FNS notes, "[t]he policy and operational issues include, but are not limited to, the preparation of the program budget, development and implementation of program policy and regulations, and identification of areas for technical assistance and training." The Academy strongly supports these goals of the CNS-OPS-II for collecting and utilizing data in light of impending legislation to reauthorize Child Nutrition Programs and to provide training to effectuate legislative and administrative policies.
B. Food Insecurity and Dietary Quality
It is the position of the Academy of Nutrition and Dietetics that systematic and sustained action is needed to achieve food and nutrition security for all in the United States. To eliminate food insecurity, a variety of interventions are needed, including adequate funding for and increased utilization of food and nutrition assistance programs, inclusion of food and nutrition education in such programs, and innovative programs that promote and support individual and household economic self-sufficiency.2 The Academy knows that adequate funding for and increased use of food and nutrition assistance programs, particularly those already incorporating nutrition education, is particularly important to improve the dietary outcomes related to food insecurity. For too many young Americans, Child Nutrition Programs provide—rather than merely supplement—their caloric intake, so enhanced, effective programs and concomitant education that help maximize the healthiness of food choices are critical.
The Academy appreciates the opportunity to comment on the information collection for CN-OPS-II. Please contact either Jeanne Blankenship at 312/899-1730 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
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Government & Regulatory 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 Holben DH. Position of the American Dietetic Association: Food insecurity in the United States. J Am Diet Assoc. 2010; 110: 1368-1377.