Academy Comments to USDA re Community Eligibility Provision Characteristics Study

July 27, 2016

Desk Officer for Agriculture
Office of Information and Regulatory Affairs
Office of Management and Budget (OMB)
Departmental Clearance Office
USDA
OCIO, Mail Stop 7602
Washington, DC 20250-7602

Re: Community Eligibility Provision Characteristics Study (OMB Control Number: 0584-NEW)

Dear Sir or Madam,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the United States Department of Agriculture (USDA) regarding its June 27, 2016 comment request "Community Eligibility Provision Characteristics Study" (OMB Control Number: 0584-NEW). 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. Every day we work with Americans in all walks of life — from prenatal care through end of life care — providing nutrition care services and conducting nutrition research.

The Academy supports the objective of the study to examine operational issues and perceived incentives and barriers for adopting CEP as well as the impacts on National School Lunch Programs and School Breakfast Program participation and per meal revenues.

The Community Eligibility Provision (CEP) allows high poverty schools to provide school meals to all students at no cost while eliminating the administrative burden and costs associated with collecting and processing household applications for subsidized school meals. A school or school district can participate in CEP if 40 percent or more of its students are eligible for free school meals, and families need not complete a take home paper application. These students are directly certified for free meals through data matching since they are in a household that receives Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), or Food Distribution Program on Indian Reservations (FDPIR), or they are certified for free meals since they are homeless, migrant, in foster care, or are enrolled in Head Start. Schools under the CEP no longer have to collect take home paper applications and dues from students, alleviating administrative burden on schools and families so food service operators can focus on feeding their students. In addition, CEP has the ability to reduce stigma for children who qualify for free and reduced school meals, because all students are similarly eligible to receive the meals. CEP was piloted in 10 states and the District of Columbia from 2011-2014 and became available nationwide for the succeeding school years.

Recent research has shown early success with the CEP. Schools have seen increased participation in school meals, decreased administrative workloads, and decreased concern about students unable to receive the meals they need.2 Additional benefits of CEP include facilitating alternative breakfast such as the "grab and go" model, and eliminating unpaid meal fees allowing schools to serve breakfasts in the classroom. In the 2015-2016 school year, more than 18,000 schools offered breakfast and lunch through CEP, and as a result more than 8.5 million children have access to healthy breakfasts and lunch every day at school. We look forward to this study and believe it will enable USDA to continue improving the CEP process.

Thank you for the opportunity to comment on the comment opportunity regarding the Community Eligibility Provision. We would be grateful for the opportunity to discuss these recommendations in greater detail in the near future with you. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.orgptuma@eatright.org with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Senior Director
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 Center on Budget and Policy Priorities and Food Research and Action Center. (2016). Community Eligibility Adoption Rises for the 2015–2016 School Year, Increasing Access to School Meals. Accessed July 23, 2016.