Academy Comments to USDA re the School Meals Data Collection Process and Associated Burden

March 6, 2017

Jinee Burdg, MPP, RDN, LDN
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, VA 22302

Re: Proposed Collection; Comments Request-Evaluation of the School Meal Data Collection Process

Dear Ms. Burdg,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA) related to its proposed collection, "Comments Request-Evaluation of the School Meal Data Collection Process," published in the Federal Register on January 5, 2017. 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 to meet the health needs of all citizens, including millions of students in schools nationwide.

The Academy supports the USDA's ongoing efforts to identify and reduce error rates in school meal reimbursement claims, verification, and direct certification. By collecting, aggregating, processing, validating, evaluating, and reporting data to reduce overclaims and underclaims, schools,local educational agencies (LEAs), state agencies, and the USDA can work together to protect the public fisc while ensuring all children—regardless of their family's income—have access to nutritious school meals.

At the same time, it is imperative that FNS evaluate how to minimize the burden of collection at the school, LEA, and state-agency levels.  Recognizing that a number of local and state agency Child Nutrition Program directors have a low error rate, we encourage FNS to focus its evaluation on states and School Food Authorities (SFAs) with high error rates to identify where and how errors occur. We are particularly concerned with the burden of verification on smaller districts, those with various student populations, and those with various staff sizes; we encourage FNS to ensure it appropriately samples them to ascertain an accurate measure of the burden imposed.

Academy members with significant experience completing verification cycles report that the process locating parents and their financial records can be difficult, very labor intensive, and needs greater evaluation and study; we would be grateful for the opportunity to open a dialogue to improve the process and reduce the burden. Issues include the amount of time required to complete the verification, the timing of studies (e.g., coinciding with particularly busy times at the beginning of a school year or summer program), and the nature of the previously uncollected data sought remain significant concerns. The Academy supports balancing time for ensuring accountability (e.g., data gathering, aggregation, and submission) and time for state agencies to provide technical assistance to LEAs with the time required for local personnel to produce nutritious school meals that children look forward to eating.

The Academy appreciates the opportunity to comment on the proposed School Meal Data Collection Process.  Please contact either Jeanne Blankenship at 312/899-1730 or by email at jblankenship@eatright.org or Pepin Tuma at 202/775-8277 ext. 6001 or by email at ptuma@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


1The 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.