The following comments were submitted by Richard Besser, MD, Robert Wood Johnson Foundation (RWJF) President and CEO, in response to the U.S. Department of Agriculture’s (USDA) “Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements” interim final rule.
Every child deserves to attend schools that provide nutritious foods and drinks and opportunities to be physically active. The recent nutrition updates to school meals have been an extraordinary achievement benefitting the 30 million children who eat school lunches, nearly three-quarters of whom qualify for free or reduced-price meals.1 For children from low-income families, school meals are an especially critical source of affordable, healthy foods.
Research shows that our nation’s schools have implemented the nutrition standards changes and are offering healthier meals. It shows that students like the lunches and are eating more of them.2 Additionally, national surveys confirm that parents support the healthier standards.3 Yet despite this clear and convincing record of success, the interim final rule would unnecessarily weaken the current standards and roll back the tremendous progress schools have made in serving healthier meals in recent years.
We urge USDA to support students’ health and well-being by fully implementing the school nutrition standards that took effect in 2012.4
The 2012 updates to school nutrition standards—the first such updates in more than 15 years—were transformative, reflecting sound science and supporting children’s health. The standards have led to meals with more fruits, vegetables, and whole grains, with far less sodium, saturated fats, and added sugars.5 Sugary drinks, unhealthy snack foods, and trans fats have been removed as well. These changes are consistent with the 2015-2020 Dietary Guidelines for Americans (DGA)6 and the National Academy of Medicine (formerly, Institute of Medicine) 2009 report School Meals: Building Blocks for Healthy Children.7
Recent demographic changes in the United States illustrate the importance of healthy school meals. According to recent data from the National Center for Education Statistics, a majority of students in our nation’s public schools—51 percent—now qualify for free and reduced-price school meals.8 In addition, with low-income, Black and Latino students at highest risk for obesity,9 ensuring that schools serve nutritious food is a core component of efforts to provide a fair and just opportunity for all children to achieve a healthy weight and mitigate the negative health effects of poverty.
Virtually all schools across the country—99 percent—have implemented the 2012 nutrition standards successfully, with more than half of states reporting 100 percent compliance.
In addition, food and beverage companies have worked diligently to reformulate and modify products to comply with the healthier standards and school budgets. The effects of industry changes have been far-reaching, even prior to the healthier standards taking effect: for example, the implementation of school beverage guidelines brokered between the Alliance for a Healthier Generation and major beverage companies resulted in a 90 percent reduction in calories from beverages shipped to schools between 2004 and 2010.10 Rolling back the standards now would send the wrong message to companies that they no longer need to prioritize their positive efforts to improve the nutritional profile of foods and beverages.
A growing body of research suggests the updated standards are working as intended:
- A Healthy Eating Research study examining 1.7 million meals served in six schools in an urban Washington school district found that the meals’ overall nutritional quality increased by 29 percent under the 2012 standards.11
- Bridging the Gap surveys of school leaders nationwide revealed widespread student acceptance of the updated standards. Seventy percent of elementary school leaders reported that students generally like the healthier school lunches; school leaders reported similar results from 70 percent of middle schoolers and 63 percent of high school students.12
- A Rudd Center for Food Policy & Obesity study examining 12 middle schools in an urban, low income school district study found that more students chose fruit after the 2012 standards went into effect (66 percent, up from 54 percent) and that students ate more of their vegetables (64 percent, up from 46 percent) and lunch entrees (84 percent, up from 71 percent).13
- A study examining low-income, predominantly minority public schools in four New Jersey cities before and after implementation of the 2012 standards found that school lunch participation between 2008 and 2015 rose slightly from 70 percent to 72 percent, while school breakfast participation held steady before rising between 2013 and 2015 from 52 percent to 59 percent. Researchers concluded that the updated nutrition standards have not affected school meal participation rates over time; students are likely to accept healthier options. 14
- A poll released by the Pew Charitable Trusts, RWJF, and the American Heart Association found that among registered voter parents with school-age children, more than 70 percent of those surveyed support the 2012 nutrition standards.15
Schools and school food service professionals have made great progress toward serving healthier meals that children enjoy eating. Since 2009, USDA has provided more than $200 million in kitchen equipment grants to help thousands of schools upgrade their facilities and infrastructure. A nationally representative survey of school nutrition directors commissioned by the Kids’ Safe and Healthful Foods Project—a joint collaboration between the Pew Charitable Trusts and RWJF—found that most meal programs use a mix of strategies to encourage students to eat nutritious meals, such as the installation of salad bars and holding taste tests with students.16
Maintaining and building on this progress is critical to helping children grow up healthy. The United States is at a crossroads in its efforts to ensure all children are able to achieve a healthy weight. The overall rise in rates of childhood obesity has slowed in recent years and some states, cities, and counties have reported declines.17 Yet the latest data show that 18.5 percent of children were obese in 2015-16, the highest rate ever recorded by the National Health and Nutrition Examination Survey18—a stark reminder that obesity continues to threaten our nation’s health, economy, and future.
Researchers from Harvard University’s T.H. Chan School of Public Health have concluded that the 2012 school nutrition standards are “one of the most important national obesity prevention policy achievements in recent decades.”19 Researchers estimate that these improvements will prevent more than two million cases of childhood obesity and save up to $792 million in health-care related costs over ten years. Given that children consume up to half of their daily calories during the school day,20 the 2012 school nutrition standards deserve USDA’s full support.
The changes to the school meals standards proposed in the interim final rule would undermine this progress.
The three-year delay in implementing the Target 2 sodium reduction levels would harm children’s health.
The 2012 standards included a multi-year plan for reducing sodium levels in school meals.21 The initial round of reductions, known as Target 1, were implemented for the 2014-15 school. The next round of reductions, known as Target 2, were scheduled to take effect for the 2017-18 school year. But Congress has delayed implementation of Target 2, and the rule proposes to push the deadline back by several more years.
Such a delay only hurts children’s health. Even with the successful implementation of Target 1 reductions, nine out of ten children still consume too much sodium,22 increasing their risk of high blood pressure, heart disease, and stroke.23 Many schools, food service companies, and others in industry are already providing healthy and appealing meals and products with less sodium. USDA should implement Target 2 and Target 3 sodium reduction levels under the current timeline, and continue to provide training and technical assistance so that all schools can meet these benchmarks.
Continuing the whole-grains waiver is unnecessary.
Eating more whole grains is associated with reduced risk of heart disease, stroke, and diabetes. Whole grains provide more nutrients and are a healthful source of fiber,24 yet children on average consume too few whole grains and too many refined grains.25 Per USDA, 85 percent of schools nationwide have not requested waivers from the current whole-grain requirements.26
Allowing flavored low-fat milk is inconsistent with expert dietary advice and school needs.
The current standards that permit only plain or flavored fat-free milk and plain low-fat milk are based on expert recommendations from the National Academy of Medicine27 which noted that the calories from flavored low-fat milk would likely push school meals past overall calorie limits due to the added sugar from the flavoring, such as chocolate or strawberry flavoring. The 2015 DGA likewise recommended “increasing the proportion of dairy intake that is fat-free or low-fat milk” and “reducing the intake of added sugars” such as those in flavored milk.28 Similarly, RWJF’s Healthy Eating Research Healthier Beverage Guidelines recommend only plain fat-free and low-fat milk for children and adolescents.29
If USDA allows flavored low-fat milk, we recommend a calorie cap of no more than 130 calories per 8 ounces, consistent with RWJF’s Healthier Beverage Guidelines.
To truly appreciate how far school meals have come in terms of improved nutrition, it is instructive to remember where they were not too long ago. As recently as the 2004-05 school year,30 43 percent of school lunches included pre-packaged foods high in calories, sodium, and saturated fat, such as burritos, pizza, or chicken nuggets. Forty-two percent of schools did not offer fresh fruits or vegetables daily in school lunches. Whole grain products were offered in fewer than 5 percent of lunches.
To say the least, the school meals students enjoy today look quite different, and the health benefits extend far beyond the cafeteria. Studies show that eating regular breakfast, including breakfast at school, has cognitive benefits, including a mainly positive effect on on-task behavior in the classroom and children’s academic performance.31 Kids can share healthy eating habits with their peers. Additionally, they can bring these lessons home, helping to empower their families to make healthy choices in their communities at grocery stores, restaurants, or farmers’ markets—even when on a tight budget.
The implementation of the current school nutrition standards has been a remarkably successful endeavor. We applaud the school officials and food service personnel who have worked diligently on behalf of the students they serve, and stand with the parents and industry leaders who have been so supportive of these efforts. We urge USDA to use its rulemaking authority to maintain and strengthen, not weaken, the current standards—especially for the 22 million children who receive free and reduced-price meals. For them, school breakfast and lunch are more than a meal; they are a lifeline. We must not let them down.
1 U.S. Department of Agriculture. National School Lunch Program: Participation and Lunches Served. 2018. https://fns-prod.azureedge.net/sites/default/files/pd/slsummar.pdf.
2 Bridging the Gap Research Brief: Student Reactions During the First Year of Updated School Lunch Nutrition Standards. July 2014. www.rwjf.org/content/dam/farm/reports/issue_briefs/2014/rwjf414549
3 Hart Research Associations memo prepared for The Kids’ Safe and Healthful Foods Project: Nationwide Polling Regarding Parents’ Views of School Meal and Smart Snacks Standards. 2014. www.rwjf.org/content/dam/farm/reports/surveys_and_polls/2014/rwjf415456
4 U.S. Department of Agriculture. Nutrition Standards in the National School Lunch and Breakfast Programs; Final Rule. Washington, DC: USDA; 2012. www.federalregister.gov/documents/2012/01/26/2012-1010/nutrition-standards-in-the-national-school-lunch-and-school-breakfast-programs
5 U.S. Department of Agriculture. School Meal Certification Data (as of September 2016). Washington, DC: USDA; 2017. https://fnsprod.azureedge.net/sites/default/files/cn/SFAcert_FY16Q4.pdf
6 U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015-2020 Dietary Guidelines for Americans, 8th Edition. Washington, DC: U.S. Government Printing Office, 2015.
7 Institute of Medicine. School Meals: Building Blocks for Healthy Children. Washington, D.C.: The National Academies Press; 2010.
8 Southern Education Foundation. A New Majority: Low Income Students Now a Majority in the Nation’s Public Schools. 2015. www.southerneducation.org/getattachment/4ac62e27-5260-47a5-9d02-14896ec3a531/A-New-Majority-2015-Update-Low-Income-Students-Now.aspx
9 Trust for America’s Health and the Robert Wood Johnson Foundation. The State of Obesity: Better Policies for a Healthier America. Inequity and Obesity. 2017. https://stateofobesity.org/inequity-obesity/
10 Am J Public Health. 2012 Oct;102(10):1928-35. doi: 10.2105/AJPH.2011.300610. Epub 2012 Aug 16. http://ajph.aphapublications.org/doi/abs/10.2105/AJPH.2011.300610
11 Johnson DB, Podrabsky M, Rocha A, Otten JJ. Effect of the Healthy Hunger-Free Kids Act on the Nutritional Quality of Meals Selected by Students and School Lunch Participation Rates. JAMA Pediatr. 2016 Jan;170(1). Doi: 10.1001/jamapediatrics.2015.3918.
12 Bridging the Gap Research Brief: Student Reactions During the First Year of Updated School Lunch Nutrition Standards. July 2014. www.rwjf.org/content/dam/farm/reports/issue_briefs/2014/rwjf414549
13 Schwartz MB, Henderson KE, Read M, et al. New School Meal Regulations Increase Fruit Consumption and Do Not Increase Total Plate Waste. Childhood Obesity. 2015;11(3). http://online.liebertpub.com/doi/pdfplus/10.1089/chi.2015.0019
14 Impact of the 2010 US Healthy, Hunger-Free Kids Act on School Breakfast and Lunch Participation Rates Between 2008 and 2015. DOI: 10.2105/AJPH.2017.304102. November 2017. www.researchgate.net/publication/321201966_Impact_of_the_2010_US_Healthy_Hunger-Free_Kids_Act_on_School_Breakfast_and_Lunch_Participation_Rates_Between_2008_and_2015
15 Hart Research Associations memo prepared for The Kids’ Safe and Healthful Foods Project: Nationwide Polling Regarding Parents’ Views of School Meal and Smart Snacks Standards. 2014. www.rwjf.org/content/dam/farm/reports/surveys_and_polls/2014/rwjf415456
16 Kids’ Safe and Healthful Foods Project. School Meal Programs Innovate to Improve Student Nutrition. 2016. www.pewtrusts.org/~/media/assets/2016/12/school_meal_programs_innovate_to_improve_student_nutrition.pdf
18 Hales CM, Carroll MD, Fryer CD, Ogden CL. Prevalence of Obesity Among Adults and Youth: United States, 2015–2016. National Health and Nutrition Examination Survey. 2017. www.cdc.gov/nchs/data/databriefs/db288.pdf
19 Gortmaker SL, Wang YC, Long MW, et al. Three Interventions that Reduce Childhood Obesity Are Projected to Save More Than They Cost to Implement. Health Aff. 2015;34:1932-9. doi:10.1377/hlthaff.2015.0631.
20 U.S. Department of Agriculture. School Nutrition Dietary Assessment Study-III. Washington, DC: USDA; 2007.
21 U.S. Department of Agriculture. Nutrition Standards in the National School Lunch and School Breakfast Programs. Sodium Reduction: Timeline & Amount. 2012. https://fns-prod.azureedge.net/sites/default/files/sodium.pdf
22 Jackson SL, King SM, Zhao L, Cogswell ME. Prevalence of Excess Sodium Intake in the United States—NHANES, 2009-2012. MMWR Morb Mortal Wkly Rep. 2016;64:1393-7. doi:10.15585/mmwr.mm6452a1.
23 Appel LJ, Lichtenstein AH, Callahan EA, Sinaiko A, Van Horn L, Whitsel L. Reducing Sodium Intake in Children: A Public Health Investment. J Clin Hypertens. 2015;17:657-62. doi:10.1111/jch.12615.
24 Harvard University T.H. Chan School of Public Health. The Nutrition Source: Whole Grains. www.hsph.harvard.edu/nutritionsource/whole-grains/. Accessed January 2018. Provides a literature review on the health benefits of whole grains.
25 Id., U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015-2020 Dietary Guidelines for Americans.
26 U.S. Department of Agriculture (unpublished). Whole Grain-Rich Exemption Take-Up by States: October 2016.
27 Id. Institute of Medicine. School Meals: Building Blocks for Healthy Children.
28 Id., U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015-2020 Dietary Guidelines for Americans.
29 Healthy Eating Research. Recommendations for Healthier Beverages. Durham, NC: Robert Wood Johnson Foundation, 2013. http://healthyeatingresearch.org/wp-content/uploads/2013/12/HER-Healthier-Bev-Rec-FINAL-3-25-13.pdf.
30 Robert Wood Johnson Foundation. Improving Child Nutrition Policy: Insights from National USDA Study of School Food Environments. 2009. www.rwjf.org/content/dam/farm/reports/issue_briefs/2009/rwjf35743
31 Adolphus K, Lawton CL, Dye L. The effects of breakfast on behavior and academic performance in children and adolescents. Frontiers in Human Neuroscience. 2013;7:425. doi:10.3389/fnhum.2013.00425. www.ncbi.nlm.nih.gov/pmc/articles/PMC3737458/