Academy Comments to USDA's Food and Nutrition Service regarding Team Nutrition in the Child and Adult Care Food Program.

January 2, 2018

Kaylyn Padovani
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Room 628
Alexandria, VA 22302

Re: Collection of Contact Information of Schools That Participate in the National School Lunch Program (NSLP) and Organizations That Participate in the USDA's Child and Adult Care Food Program (CACFP) for Sharing Team Nutrition's Nutrition Education, Training, and Technical Assistance Resources

Dear Desk Officer,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Food and Nutrition Service (FNS) related to its November 2, 2017 information collection, "Collection of Contact Information of Schools That Participate in the National School Lunch Program (NSLP) and Organizations That Participate in the USDA's Child and Adult Care Food Program (CACFP) for Sharing Team Nutrition's Nutrition Education, Training, and Technical Assistance Resources." 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 supporting distribution of evidence-based materials to enhance the effectiveness of child nutrition education and thus improve adult health outcomes.

The Academy supports this information collection as necessary for the proper performance of the functions of the FNS and will have significant practical utility due to its potential to facilitate distribution of effective nutrition education materials to CACFP organizations.

A. Significance of Team Nutrition for CACFP

We agree with the FNS goal of providing timely announcements at regular intervals to facilitate distribution of useful materials via various media. Along with suitable training, such timely distribution will help bring CACFP organizations into compliance with Team Nutrition standards as well as the Dietary Guidelines for Americans. We also note that the burden placed upon respondents is not unreasonable.

B. Survey Enhancement

FNS is encouraged to ensure that education materials are culturally-appropriate for the population served. That includes ensuring nutrition recommendations are culturally-sensitive as well as expressing culturally-supportive images and messages. Additionally, FNA might consider ensuring that each nutrition education tool is available in each language referenced on the FNS webpage "Documents Available in Other Languages."2 Such features can substantially increase the understanding by provider staff, and thus increase utility of the recommendations and the overall appeal of the document/media itself.

Given the increasing diversity of CACFP populations and their respective diets, FNS might also consider recognizing diversity parameters beyond race and ethnicity, such as religion, as well as various food allergies and preferences, such as nut allergies and meat-free or dairy-free diets.

We also encourage continued emphasis on providing low-literacy materials, since CACFP providers may not possess formal academic training in nutrition or related fields. Maintaining such standards thereby supports provider understanding, and thus client understanding as well.

C. Conclusion

The Academy appreciates the opportunity to comment on the proposed information collection for the "Collection of Contact Information of Schools that Participate in the National School Lunch Program (NSLP) and Organizations that Participate in the USDA's Child and Adult Care Food Program (CACFP) for Sharing Team Nutrition's Nutrition Education, Training, and Technical Assistance Resources" docket. Please contact either Jeanne Blankenship at 312-899-1730 or by email at jblankenship@eatright.org or Mark Rifkin at 202-775-8277 ext. 6011 or by email at mrifkin@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

Mark E. Rifkin, MS, RD, LDN
Manager
Consumer Protection and Regulation
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 "Documents Available in Other Languages." https://www.fns.usda.gov/documents-available-other-languages, Accessed December 28, 2017.