February 12, 2018
Director, Policy and Program Development
Child Nutrition Programs, Food and Nutrition Service
P.O Box 66740
St. Louis, MO 63166-6740
Re: Food Crediting in Child Nutrition Programs: Request for Information (FNS-2017-0044)
Dear Ms. Kline,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Nutrition Service (FNS) related to its December 14, 2017 information collection, "Food Crediting in Child Nutrition Programs: Request for Information (FNS-2017-0044)." Representing more than 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 and is committed to developing, promoting, and providing comprehensive, integrated nutrition services in schools, kindergarten through grade 12, that improve the nutritional status, health, and academic performance of our nation's children
The Academy supports this request for information (RFI) as necessary for the proper performance of the functions of the FNS and appreciates "the chance to share [our] thoughts and opinions on crediting and gather ideas that maximize program operators' ability to serve healthy, appealing meals."2 Accordingly, we respectfully offer the following comments and specific answers to the questions posed in FNS's RFI.
A. The Academy's Position and Overarching Considerations
It is the position of the Academy of Nutrition and Dietetics that children and adolescents should have access to an adequate supply of healthful and safe foods that promote optimal physical, cognitive, and social growth and development. Nutrition assistance programs, such as food assistance and meal service programs and nutrition education initiatives that also serve at-risk adults, play a vital role in meeting this critical need. In addition, federally funded nutrition assistance programs serve as a means to combat hunger and food insecurity and as a vehicle for nutrition education and promotion of physical activity designed to prevent or reduce obesity and chronic disease.3
The Academy strongly supports the 2015 Dietary Guidelines for Americans' (DGA) emphasis on food patterns and meal patterns rather than an excessive focus on macronutrients and micronutrients that has significant unintended consequences for nutrition policy. Further, we strongly support incorporating these elements of the DGA into food crediting determinations in Child Nutrition Programs. In addition, our dietetic practice groups agreed that Child Nutrition Programs should emphasize whole foods and further agreed that teaching children how to eat is a goal of these programs on par with simply feeding them.
B. Nutrition Education and Goals of Team Nutrition
Nutrition education is absolutely essential; it strongly enhances the likelihood of successfully achieving the goals of Child Nutrition Programs, including children's acceptance of provided meals and snacks.. And RDNs, with their training in both food service management and their nutrition expertise, are uniquely qualified not only to develop and provide effective nutrition education but also to plan nutritious and appealing meals. Academy members note that to enhance revenue, cafeterias could be considered as restaurants, with significant marketing efforts such as taste tests among children key to increasing sales. We encourage FNS to ensure that education materials are culturally-appropriate for the population served, which includes ensuring nutrition recommendations are culturally-sensitive as well as expressing culturally-supportive images and messages.
We appreciate FNS's interest in comments that are consistent with the current statutory framework for the Child Nutrition Programs. Specifically, we note the importance of factoring in the goals and purposes of the effective Team Nutrition and MyPlate initiatives. As FNS details:
The Dietary Guidelines for Americans are the basis of federal nutrition policy, education, outreach, and food assistance provided through the Child Nutrition Programs. The Team Nutrition initiative helps schools, child care settings, summer meal sites, parents/ caregivers, and children put the Dietary Guidelines for Americans into action through training, technical assistance, and nutrition education. The MyPlate icon uses a familiar image—a place setting for a meal—to prompt consumers to build a healthy plate at mealtime. MyPlate also illustrates the five food groups, reminding everyone that these foods are the building blocks of a healthy diet."4p>
A study by the USDA's Economic Research Service found that "[m]ost issues related to the NSLP touch upon, in one way or another, two, if not all three, components of a school meal "trilemma" involving the meal's nutrition, program cost, and student participation in the program."5 Significantly, this same study found that
Several studies show that schools could reduce the fat content of foods offered and increase consumption of underconsumed foods, such as milk and vegetables, while still maintaining revenue levels and NSLP participation levels. This can be done by exposing students to new foods, updating menus, changing the way food is presented, and providing nutrition education. USDA has assisted schools in this effort by providing grants for educational resources through its Team Nutrition initiative and by including lower fat foods as part of the commodities it donates to the program.6This goal to emphasize creating appealing meals and effective nutrition education has also been adopted by states, including South Carolina, which in 2004 identified a new goal for school meals: to make them "attractive to students by appealing to their taste preferences and cultural needs."7
C. RFI Questions
1. Is it appropriate to continue to credit foods based on the volume or weight served, with the few exceptions discussed above? Why or why not?
Crediting (or identifying a portion size) based on volume is consistent with USDA's Food Guidance systems, currently MyPlate. Current crediting practices can be managed through the USDA Buying Guide. In addition, as many schools switch back to scratch cooking, weights are helpful in determining recipe yield and portioning. Also, as many schools offer fresh fruit and veggie bars that are self-serve, volumes are helpful for determining meal reimbursement (i.e., eyeballing whether or not they have taking a combination of fruits and vegetables that add up to a 1/2 cup equivalent). Crediting for the value served, and not offered, is important. Americans, including children between the ages of 2-19, do not consume the daily recommended servings of fruits and vegetables. A diverse and colorful array of fruits and vegetables throughout the week helps increase nutrient intake and ensure students are exposed to a variety of options.
However, the Academy has concerns with the exceptions FNS discussed. Specifically, it is inconsistent to credit tomato puree and tomato paste by the reconstituted volume, which seems contrary to the FNS policy of crediting foods on the customary use of the products. The school cafeteria and the CNP meal patterns serve as a nutrition education learning laboratory. The meal patterns and food choices offered in the cafeteria help children to learn to make healthy choices and learn portion control. Crediting a tablespoon of tomato paste as equal to a 1/4 cup of vegetable is contrary to this process. It also conflicts with the MyPlate and Team Nutrition nutrition education messages. Recognizing the applicability from a purely nutritional standpoint, some members believe the exceptions can be accommodated and taught through adequate training, reinforced through detailed production records and scoop sizes, and student marketing showing students how to self-select. These accommodations do not wholly ameliorate our concerns, and we encourage FNS to consider whether the exceptions merit exposing inconsistent messaging and abrogation of Team Nutrition's goals of serving appealing nutritious meals that children choose to eat and providing them with consistent nutrition education messages, rather than sneaking nutrients into meals simply to meet specified nutrition standards.
2. What are the benefits and negative impacts of having different crediting values for different forms of vegetables and fruits?
Benefits of having different crediting values for different forms of vegetables and fruits include the fact that experienced individuals may be able to visually judge appropriate amount. However, the negative impacts can overwhelming to new staff upon hiring. Training on reimbursable meals becomes complicated, and there is substantial potential for confusion and inconsistent messaging with MyPlate, Team Nutrition, and the DGA.p> The Academy associates itself with the comments submitted by United Fresh Produce stating that:
The benefit of the current crediting values, particularly for school breakfast and lunch, is that students are exposed to both a wide variety of fruits and vegetables, and the recommended portion sizes, consistent with the DGA. As reflected in USDA's final rule for nutrition standards, the 2005 and 2010 DGA recommend eating a variety of vegetables, especially dark green and red and orange vegetables and beans and peas. These specific subtypes provide children with a number of nutrients that are currently under-consumed: dietary fiber; folate; magnesium; potassium; and vitamins A, C, and K. Maintaining these subtypes are important to student health and building healthy habits.
Relative to crediting values across forms of fruits and vegetables, the DGA recommends that fruits and vegetables should be consumed in all forms, preferably whole, and cautions consumers to consider the addition of added sugar and sodium in certain canned, dried or frozen products when making food choices.
Intake recommendations are different across forms of fruits and vegetables, with the DGA making recommendations of fruit and vegetable intake based on overall daily caloric recommendations. For example, an individual with a 1,600 calorie diet should consume four servings of fruits and between four and five servings of vegetables per day. A serving is measured as the following: 1 medium fruit; or ¼ cup dried fruit; or ½ cup fresh, frozen, or canned fruit; or ½ cup fruit juice (the DGA recommends limiting fruit juice consumption due to lack of fiber and increased caloric intake). School lunch and breakfast programs should maintain crediting values consistent with the DGA.
3. Should fortification play a role in determining if and how a food is credited in the Child Nutrition Programs? Why or why not?
In general, fortification should not play a role in crediting. People eat food, not nutrients, and the food group system of crediting food is consistent with MyPlate, Team Nutrition and the DGA. However, fortification could play a role if and only if concerning vegan or vegetarian options, but not to replace meat or disguise, hide, or stretch meat products. For example, if tempeh is to be added as a creditable vegan protein option, it may be fortified to meet the standards set forth, but a hamburger that has non-meat or low quality fillers that are fortified to be nutritionally similar to meat only to be sold as a cheaper alternative should not. As we shift to more meatless protein options for various reasons (e.g., sustainability, environmental purposes, and to be able to meet the protein demands of a growing world population), we must be able to serve high quality, whole foods to children that contain high quality protein from intact, whole foods, not supplemented to meet standards through fortification. Notably, with regards to dairy and certain other beverages, fortification can be valuable due to the deficiencies and overall shortfalls for calcium and Vitamin D we seen in our population.
4. Is the presence of certain nutrients more important than other nutrients when determining if and how a food credits in the Child Nutrition Programs? Why or why not?
FNS should retain its policy of crediting foods on the customary use of the products (e.g., a pudding that contains a high protein, soy fortification should not be credited as a meat/meat alternate). This sends the wrong message for the goal of teaching children to make healthy choices. The most important nutrient to consider for meat/meat alternates specifically would be the macronutrient of protein, recognizing that protein qualities can vary tremendously (i.e., bioavailability and amino acid content). By focusing on each component independently, we lose the nutritional impact of the meal as a whole.
The main nutrients of concern in children and teens in the US are calcium, magnesium, potassium, and fiber. Through fortification of milk and even juices for our non-milk drinkers (which is a growing part of our diverse student population), we can ensure that calcium is a part of our student's diets. Nuts, beans, whole grains, and dark leafy greens are the main sources of magnesium that can be achieved through whole foods. Fruits, vegetables, and milk are high in potassium and can be achieved through whole foods. Fiber is high in fruits, vegetables, and whole grains. Overall, our children's nutrients can generally be met through whole foods without encouraging fortification.
5. If a food product does not have a federal standard of identity or industry standards for production, how could these food products credit in the Child Nutrition Programs? Please be as specific as possible.
Food products that lack an industry standard could be credited through their nutrition label. For example, a soy chorizo product that is not currently creditable but has a substantial amount of high quality protein per serving could potentially be credited through protein to meat/meat alternate equivalents.
6. Is it appropriate to continue to consider the customary use of a product when determining how a food credits in the Child Nutrition Programs? Why or why not?
FNS should continue its policy of crediting foods on the customary use of the products. The school cafeteria and the CNP meal patterns serve as a nutrition education learning laboratory. The meal patterns and food choices offered in the cafeteria help children to learn to make healthy choices and learn portion control. We encourage FNS to be consistent in this regard in all programs, as organizations running multiple programs report that the burden of differing regulations can result in exorbitant inventories, a lack of storage space, and over complicated menu systems.
7. What role should such educational considerations play in determining the creditability of a food in the Child Nutrition Programs?
Educational considerations should play a great role, as noted above in sections A and B. The USDA food grouping system, currently MyPlate, has always been an important way to convey nutrition messages to the public, including children. The school cafeteria should serve as a nutrition education laboratory. The Academy believes that Child Nutrition Programs should teach nutrition through the variety of options offered and should not focus on one component or even one meal. Nutrition is about balance across a lifetime. The role of Child Nutrition Programs is to allow students to try a variety of food, expand their palate, serve foods that they love, and show a balanced menu daily all while ensuring that no child goes hungry.
8. Are there other factors FNS should consider in determining how foods credit in the Child Nutrition Programs? Why or why not?
The Academy encourages FNS to allow room for culturally specific items and to ensure crediting discussions are looked at from multiple cultural perspectives.
9. Are there additional ways FNS can make the crediting process more simple, fair, or transparent? Please be as specific as possible.
The crediting process thus far has made it so that it is easier and less time consuming for programs to use and rely on purchased products and move away from scratch-cooked recipes due to the complexity in calculating contribution equivalents. While the USDA has provided base recipes that assist in this process, many of the examples provided are not culturally relevant to all districts. Labeling also favors larger companies because many of the smaller companies cannot afford child nutrition credentialing and it can be overwhelming to try to work with small, local manufacturers to insist that they fill out an ingredient statement to verify the product's crediting. We encourage FNS to develop and disseminate resources for small companies to assist with the process in a step-by-step fashion that go beyond providing webinars.
10. Are Child Nutrition Program operators currently offering any of these foods as an extra item that does not contribute to the Child Nutrition Programs' meal patterns? If so, which ones?
Some members reports that they not currently providing beef jerky as a part of a meal but do offer it a la carte and it is popular with adolescents as a high protein after-school snack option. Others were considering adding a California Roll to the grab-n-go line but could not find a way to make a vegetarian/pescatarian roll into an affordable reimbursable meal without the use of surimi.
11. Should FNS allow any of these foods to contribute to the Child Nutrition Programs' meal patterns? Why or why not?
Some of these foods are a good source of protein and could account for that component, but sodium should be a consideration given the levels in many of these snack foods, such as beef jerky and summer sausage. Schools are now struggling to lower the sodium in school meals, and allowing the crediting of the high sodium content foods may exacerbate the problem.
12. If any of these foods are allowed to contribute to the Child Nutrition Programs' meal patterns, how should they be credited? Be as specific as possible, such as the volume or weight needed, or a specific nutrient content.
- Is there an ingredient or processing method that would qualify or disqualify these products?
13. If any of these foods are allowed to contribute to the Child Nutrition Programs' meal patterns, would Child Nutrition Program operators incorporate these foods into menus to meet the meats/meat alternates requirement? Why or why not?
Members report that shelf-stable protein options like jerky are helpful for field trips as well as emergency meals. In addition, members report that surimi would be popular with their students.
- If yes, how would they be served (e.g., at snack, as part of a reimbursable lunch)?
They could be served as either an afterschool snack, at CACFP, or for lunch.
14. If any of these foods are allowed to contribute to the Child Nutrition Programs' meal patterns, how would this impact the Child Nutrition Programs, including its participants and operators? What are the potential benefits and negative impacts?
Dried meats are central to the historical Native American diet and there are many local producers so it would be great to develop a menu based off of traditional recipes and use locally sourced products. In addition, many students that have fish as a their principal protein source in their home diets would welcome an affordable additional option. Substantial negative impacts that FNS should consider include amounts of sugar and sodium in jerky.
15. Are Child Nutrition Program operators currently offering high protein yogurt as part of a reimbursable meal?
We are not because the high cost (due to the additional processing requirements) is prohibitive as it does not credit any higher than regular yogurt which is more affordable.
16. Should FNS create a separate crediting standard for high protein yogurt that is different than the crediting standard for traditional yogurt for the Child Nutrition Programs? Why or why not?
The Academy received mixed input for answering this question. Some members believe if high protein yogurt has a higher protein content, it should be reflected in the crediting of oz M/MA. These members noted that yogurt is healthy and well received among youth, and that in programs where 1.5-2 oz M/MA is required, students are not likely to take and consume 6-8 oz of yogurt as it is too much food for a 4-year-old pre-K student to eat. Other members opposed a separate crediting standard, because allowing the crediting of a reduced volume of high protein yogurt is getting back to nutrient counting and is contrary to food grouping of MyPlate, Team Nutrition, and the DGA. These members noted that a separate crediting standard adds to the complexity of the program for school food service professionals and the children that have traditionally learned food and portion amounts from the school meal patterns.
17. If high protein yogurt is allowed to contribute differently to the Child Nutrition Programs' meal patterns than traditional yogurt, how should high protein yogurt be credited? Be as specific as possible, such as the volume or weight needed.
If it is allowed to contribute differently, the labeling should be commensurate with the protein of regular yogurt: 4 oz regular yogurt= 3 g protein and 1 oz M/MA; 4 oz Greek yogurt= 10 g protein and 3 oz M/MA.
- Is there an ingredient or processing method that could qualify or disqualify a particular yogurt from crediting in the Child Nutrition Programs (e.g., a particular thickening agent could disqualify a high protein yogurt)?
Sugar should be limited to no more than 16 g per 4 oz serving, with potential modifications once all nutrition labels differentiate naturally occurring vs. added sugars.
18. If high protein yogurt is allowed to contribute differently to the Child Nutrition Programs' meal patterns than traditional yogurt, would Child Nutrition Program operators take advantage of using it to meet the meats/meat alternates requirement? Why or why not?
Members report operators would take advantage of using high protein yogurt, as it provides a high protein vegetarian option that is easily digestible, enjoyed by children, and asked for by parents.
- If yes, how would Child Nutrition Program operators serve it (e.g., at snack, as part of a reimbursable lunch)?
Although some operators would be likely to use it for breakfast, lunch, after school snack, CACFP, and summer programs as well as a la carte if it qualified, others are concerned about potentially increased costs and the added complexity of including it.
19. If high protein yogurt is allowed to contribute differently to the Child Nutrition Programs' meal patterns than traditional yogurt, how would this impact the Child Nutrition Programs, including its participants and operators, as well as food manufacturers? What are the potential benefits and negative impacts?
Members provided varied input on anticipated cost effects, but reported a likely reduction in food waste. We encourage FNS to study cost effects and impact on food waste before making a change to credit high protein yogurt differently.
20. Are Child Nutrition Program operators currently offering any of these foods as an extra item that does not contribute to the Child Nutrition Programs' meal patterns? If so, which ones?
Some programs offer some items like baked potato chips, kale chips, and popcorn as a la carte items or occasionally as non-creditable accompaniments of meals. In general, the Academy does not support encouraging highly processed snack foods into the meal patterns, and we support doing more scratch cooking to reduce sodium and fat. We encourage FNS to consider results of School Nutrition Dietary Assessment studies highlighting concerns of high sodium, high fat snack foods.
21. Should FNS allow any of these foods to contribute to the Child Nutrition Programs' meal patterns? Why or why not? If so, which ones?
The Academy at this time did not receive significant input supporting allowing these foods to contribute to CNP's meal patterns.
22. If any of these foods are allowed to contribute to the Child Nutrition Programs' meal patterns, how should they be credited? Be as specific as possible, such as the volume or weight needed, or a specific nutrient content.
- Is there an ingredient, processing method, or nutrient standard (e.g., sodium content) that should qualify or disqualify any of these foods?
If they qualified for the program, the sodium content would need to fit into the overarching CNP meal patterns.
23. If any of these foods are allowed to contribute to the Child Nutrition Programs' meal patterns, would Child Nutrition Program operators incorporate them into menus to meet the Child Nutrition Programs' meal patterns? Why or why not?
Members indicate an interest in including whole grain popcorn as an afterschool snack item if choking concerns in the youngest students could be addressed. Baked potato chips would not be offered as a standalone vegetable option for the day.
- If yes, how would they be served (e.g., as part of a reimbursable snack)?
They could be served for afterschool snack and lunch.
If any of these foods are allowed to contribute to the Child Nutrition Programs' meal patterns, how would this impact the Child Nutrition Programs, including its participants and operators, as well as food manufacturers? What are the potential benefits and negative impacts?
Whole grain popcorn is a child-friendly item that can be customized with different seasonings, is highly affordable, and equipment for air popping is also affordable.
Are there additional products not mentioned in this request for information that are currently not creditable, but you would wish to provide comments on? Please be as specific as possible.
The Academy appreciates the opportunity to comment on the proposed information collection for the "Food Crediting in Child Nutrition Programs: Request for Information" docket. 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.
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 Seeks Public Input on Child Nutrition Food Crediting. FNS website. Published December 14, 2017. Available at https://www.fns.usda.gov/pressrelease/2017/016817. Accessed February 5, 2018.
3 Stang J, Bayerl CT. Position of the American Dietetic Association: Child and Adolescent Nutrition Assistance Programs. J Am Diet Assoc. 2010;110(5):791-99.
4 Team Nutrition. FNS website. Published October 19, 2016. Available at https://www.fns.usda.gov/tn/about-team-nutrition. Accessed February 5, 2018.
5 National School Lunch Program: Background, Trends, and Issues. https://www.ers.usda.gov/webdocs/publications/46043/12050_err61_reportsummary_1_.pdf?v=41056 Economic Research Service July 2008 U.S. Department of Agriculture
7 Tenenbaum, Inez. 2004. "South Carolina Department of Education Recommendations for Improving Student Nutrition and Physical Activity," South Carolina Department of Education. Available at http://www.fns.usda.gov/sites/default/files/SC_report.pdf. Accessed February 1, 2018.