Academy Urges USDA to Improve School Nutrition and Meal Cost Study

July 26, 2019

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RE: School Nutrition and Meal Cost Study-II (SNMCS-II) (OMB Number: 0584-NEW)

Dear All:

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Nutrition Service of the U.S. Department of Agriculture related to its request for feedback on the School Nutrition and Meal Cost Study-II (OMB Number: 0584-NEW), originally published in the Federal Register on June 27, 2019 (84 FR 30690). Representing over 100,000 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 United States. We are committed to accelerating improvements in the nation’s health and well-being through food and nutrition.

The Academy supports SNMCS-II data collection efforts and found the data and results of the SNMCS-I study to be informative and useful for a large range of stakeholders including district and school level staff, school nutrition operators, as well as local, state, and federal policy makers. Since the last SNMC-I data collection effort a number of issues have developed (i.e. decreased paid level lunch participation rates, unpaid meal debt and subsequent 'lunch shaming', changes in national nutrition standards) that impact the National School Lunch and Breakfast programs and the Academy urges USDA to consider making changes to the survey instrument and methods to improve the clarity and utility of the data collection.

A. Practical utility of the SNMCS

The Academy supports continued efforts to collect evaluative data on the National School Lunch and Breakfast programs. The School Nutrition Dietary Assessment Studies (SNDA I, II, III and IV) from 1992 to 2010 provided valuable comprehensive information for policy makers, administrators, school food authorities, and nutrition and health professionals as to the degree of schools' compliance with federal nutrition standards and policy, student acceptability of reimbursable school meals, the sale and revenue from other foods sold on campus and total student dietary intake over comparable days.

The newly released SNMCS I added the evaluation of meal costs and revenues for producing reimbursable school meals (both breakfast and lunch). According to the study, the changes to the school meal nutrition standards significantly increased the dietary quality of both the lunch and breakfast program offerings. The Healthy Eating Index scores for lunch and breakfast increased by 41 and 44 percent, respectively, since the Healthy Hungry Free Kids Act changes were implemented. The menu changes reflect an increase in whole-grains, fruits and vegetables and a decrease in sodium, refined carbohydrates and excess calories. In short, the study provided great utility in that it confirmed that strong nutrition standards work.

The study also provided information on compliance with daily and weekly meal pattern requirements and outlined the areas needed for continued technical support and training, which will be important to note as the Academy and others continue to support alignment of the nutrition standards with the Dietary Guidelines for Americans. This information will help USDA target and develop resources and tools for the school meal programs and provide future direction for policy changes.

The SNMCS-II will provide important data with current information about how school meal programs are operated, and by comparison with SNMCS I, will indicate trends in nutritional content of school meals, meal costs and revenues, plate waste and total dietary intakes of students over comparable school days.

B. Estimate of burden for data collection

In the original announcement for information collection, it was stated that the estimated time per response is 33 minutes but elaborated that the estimated response per data collection activity varies from 1 minute to 10.25 hours. In many instances, the same person is responding for several data collection activities, e.g., the state Child Nutrition Program Director, the School Food Authority Director, the School Nutrition Manager, etc. are listed as respondents for several activities. An indication of time burden per respondent would be helpful.

The Academy suggests notifying respondents months in advance so they have adequate time to compile all of the information necessary to scan and submit items such as food labels, recipes, food production records, food purchasing records, etc. FNS might consider developing a webinar(s) for an overview of the study following notification, while providing initial training for all respondents on the data to be collected and the forms that will be used for data collection.

C. Opportunities to enhance the quality, utility, and clarity of collected information

Sampling methodology
Upon review of the sampling methodology for SNMCS-I, the Academy would like FNS to consider a more robust and comprehensive on-site sampling plan for SNMCS-II. Since 52% of all school districts have fewer than 1000 students, the samples need to reflect the various dynamics of the program nationally. Specifically, Academy members questioned whether the finding from SNMCS-I that suggested meals with higher HEI scores did not cost more to produce than meals with a lower HEI score could have been impacted by the sampling methods given the general understanding that healthy food is often more expensive. In addition, it would be helpful to include sampling of public and non-public charter schools, which could identify unique challenges in these types of schools and could inform technical assistance and training gaps for USDA.

Decrease in Paid Level Student Meal Participation
The NSLP provided low-cost or free lunches to 29.7 million children daily in 2018; participation has declined in six of the last seven years.2 The biggest decline has been seen in the paid student category. According to SNMCS-I, in SY 2014–2015, a 10 cent increase in the price of a paid lunch was associated with a decline of 0.7 percentage points in the rate of paid meal participation in the NSLP. The Academy is concerned that the Paid Lunch Equity provision from HHFKA is out-pricing paid students from the program and is limiting the reach and impact of the newly improved school nutrition environment for all students and encourages FNS to consider collecting additional information to explain this association in more detail.

Unpaid Meal Debt
According to the School Nutrition Association's operations study and repeated, recent news reports3,4,5, school meal programs continue to face challenges when students who are not enrolled in the free meal program lack adequate funds to pay for their meals. These unpaid meal debts have led to cases of 'lunch shaming'. In turn, there have been a handful of state level bills as well as efforts to introduce federal policies to address 'lunch shaming'. However, there are reports from Academy members that some state level anti-lunch shaming legislation has increased the unpaid meal debt. This is a serious issue that needs well developed policy to address both the real burden of unpaid meal debt as well as the negative consequences of lunch shaming. In order to make appropriate policy decisions, there needs to be a better understanding of who is incurring the unpaid meal debt and what, if any, unintended consequences may be occurring while state level anti-lunch shaming bills are implemented. The SNMCS-II is an ideal vehicle to collect some of the financial data needed to better address this issue and the Academy suggests that FNS consider adding questions to the survey instrument to capture this information.

Food Waste
SNMCS-I concluded that schools with the highest HEI scores had the highest level of student participation. This finding was important in that it supported student acceptability of changes in nutrition standards. According to the study, there has not been a significant increase in plate waste as compared to before the HHFKA. However, upon further review of previous plate waste data points, it was difficult to draw a direct comparison between the plate waste data from SNMC-I and previous studies. The Academy suggests that USDA review the raw data from previous plate waste studies to see if a direct comparison from food group to food group can be made to better illustrate plate waste trends before and after HHFKA.

D. Conclusion

The Academy appreciates the opportunity to submit comments to USDA related to its request for feedback on the School Nutrition and Meal Cost Study-II. The Academy urges USDA to consider making changes to the survey instrument and methods to improve the clarity and utility of the survey and capture information about current topics where limited data is currently available. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Liz Campbell at 202-775-8277 ext. 6021 or by email at ecampbell@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

Liz Campbell, MA, RDN
Senior Director
Legislative & Government 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 USDA. National School Lunch Program. Accessed July 26, 2019.

3 https://www.cnn.com/2019/05/12/politics/school-lunch-shaming-children-debt/index.html

4 https://www.cnn.com/2019/07/20/us/pennsylvania-school-lunch-debt-trnd/index.html

5 https://www.bostonglobe.com/opinion/letters/2019/06/20/mass-should-move-fast-protect-pupils-from-lunchshaming/Ci7HT26JApNQkGWh9Djc2O/story.html