July 31, 2017
Ashley Chaifetz, Ph.D.
Social Science Research Analyst
Special Nutrition Evaluation Branch
Food and Nutrition Service, USDA
3101 Park Center Drive
Alexandria, VA 22302
Re: Study of School Food Authority (SFA) Procurement Practices (SFA Procurement Practices Study)
Dear Dr. Chaifetz,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to comment on the Food and Nutrition Service (FNS) of the United States Department of Agriculture's (USDA's) comment request regarding its Study of School Food Authority (SFA) Procurement Practices. Representing over 100,000 registered dietitian nutritionists (RDNs),1 nutrition dietetic technicians, registered (NDTRs),2 and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States committed to a world where all people thrive through the transformative power of food and nutrition, including millions of students in schools nationwide.
The Academy generally supports FNS's proposal to conduct "one of the first FNS studies of SFA procurement practices for school meal programs to comprehensively examine food service management companies, group purchasing agreements, recordkeeping, local food purchases, and food purchase specifications." We agree that "[t]he SFA Procurement Practices Study will assist FNS to better understand SFA procurement practices by identifying the ways SFAs make decisions about procuring goods and services and the outcomes of such decisions." To assist FNS in this process, Academy members with significant experience in school procurement practices offer the following comments to enhance the quality, utility, and clarity of the information to be collected.
The data collected is necessarily a result of the lack of sufficient training for Local Education Agencies (LEAs) on procurement practices. We encourage FNS to work with states to provide additional training opportunities prior to assessment and ultimately data collection, analysis and corrective action. In Illinois, for example, LEAs were asked to submit procurement data they may have been audited on even though the Illinois State Board of Education is not offering its first procurement training until late summer. This lone training will only be offered in a single location more than 3.5 hours from one member’s school district. Academy members in other states similarly report that only a single training is held with little notice, often far from home, and at dates not conducive to improving procurement practices prior to assessment.
Collecting data from LEAs before training them on procurement is analogous to testing students before the course content is taught and the student comprehends it. It would provide little value to test students in that way, and it provides little value other than as a "pre-test" score to assess procurement practices prior to trainings. The Academy strongly encourages FNS to work with states to ensure more training is provided either before or in conjunction with this study. If the study reaches out to LEAs who have yet to receive adequate training on procurement, FNS should recognize the impact this will have on the data to be analyzed.
The Academy supports FNS’s efforts to study procurement practices and offers our assistance in conducting this important initiative. Please contact either Jeanne Blankenship by telephone at 312/899-1730 or by email at email@example.com or Pepin Tuma by telephone at 202/775-8277, ext. 6001 or by email at firstname.lastname@example.org 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, JD
Sr. Director, Government & 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 NDTRs are educated and trained at the technical level of nutrition and dietetics practice for the delivery of safe, culturally competent, quality food and nutrition services. They are nationally credentialed and are an integral part of health care and foodservice management teams. They work under the supervision of a registered dietitian nutritionist when in direct patient/client nutrition care; and often work independently in providing general nutrition education to healthy populations.