Comments from Richard Besser, MD, on Proposed Changes to USDA's School Nutrition Standards

The following comments were submitted by President and CEO Richard Besser, MD, of the Robert Wood Johnson Foundation, in response to the U.S. Department of Agriculture’s (USDA) proposed rule on school nutrition standards based on the Dietary Guidelines for Americans, 2020–2025.

The Robert Wood Johnson Foundation (hereinafter “RWJF”) appreciates the opportunity to comment on the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS)’s proposed rule, Child Nutrition Programs: Revisions to Meal Patterns Consistent With the 2020 Dietary Guidelines for Americans (hereinafter “2023 Proposed Rule”).

RWJF is committed to improving health and health equity for all in the United States. In partnership with others, we are working to develop a Culture of Health rooted in equity that provides every individual with a fair and just opportunity to thrive, no matter who they are, where they live, or how much money they have.

Health is more than an absence of disease. It is a state of physical, mental, and emotional wellbeing. It reflects what takes place in our communities, where we live and work, where our children learn and play, and where we gather to worship. That is why RWJF focuses on identifying, illuminating, and addressing the barriers to health caused by structural racism and other forms of discrimination, including sexism, ableism, and prejudice based on sexual orientation.

We rely on evidence to advance health equity. We cultivate leaders who work individually and collectively across sectors to address health equity. We promote policies, practices, and systems change to dismantle the structural barriers to wellbeing created by racism. We work to amplify voices to shift national conversations and attitudes about health and health equity. Our comments are grounded in the perspectives and expertise of our grantees, who include academic researchers, policy experts, advocates, and organizers with deep expertise in supporting health in childhood.

For roughly two decades, RWJF has invested in efforts to improve access to healthy foods for children and families and to reduce the risk of childhood obesity, including through school meals. Few programs have as much ability as school meals to make broad and significant strides for the health of children and families. School meals are one of the healthiest sources of foods for school-age children, which is significant as some children receive up to half of their daily calories at school. Further, school meal programs are an essential tool to advance health and racial equity because they reach every child in the U.S. who attends public school.

Our national program Healthy Eating Research (HER) has a substantial body of evidence documenting how improvements to school meals improves nutrition. Most recently, HER published a new Health Impact Assessment (HIA) demonstrating that fully aligning school meal nutrition standards with the 2020-2025 Dietary Guidelines for Americans (DGA) would improve students’ health and diet quality, help their academic performance, reduce overweight and obesity rates, and decrease food insecurity. Healthier meals are also likely to increase student participation in school breakfasts and lunches, which can boost revenue for schools.

In prior analyses, HER found that the updates to school meal nutrition standards following implementation of the 2010 Healthy, Hunger-Free Kids Act (HHFKA) improved the nutritional quality of school meals by more than 40 percent. Without the HHFKA updated standards, researchers estimate that obesity prevalence among children living in families at or below the federal poverty level would have been 47 percent higher by 2018. Moreover, schools serving the healthiest meals tend to have the highest rates of participation in meals programs and see no increase in kids throwing food away. The HHFKA updated nutrition standards also reduced disparities in the nutritional quality of school meals: since implementation of the HHFKA nutrition standards, there have been no reported differences in the quality of school meals served across socioeconomic status, race, and ethnicity.

The 2023 Proposed Rule would continue these significant, positive steps in the right direction. To maximize the potential positive impact of the 2023 Proposed Rule on the more than 30 million students who eat school meals each day, we offer the following opinions and recommendations for areas where USDA can strengthen the proposal.

Recommendations for Implementation

We urge USDA to finalize the 2023 Proposed Rule and to implement the limits on added sugars and sodium on a faster timeline. Added sugars weekly limits would not meet DGA recommendations until 2027, and sodium levels would not meet FDA’s guidelines for industry until 2029. We strongly believe that implementing these updates will be hugely beneficial for the health of all children, and because of that ought to be done as soon as is feasible.

We acknowledge that food service programs cannot incorporate new nutrition standards alone, especially when inflation is high and supply chain and staffing challenges continue. However, food service programs have demonstrated that they can adapt to change on a rapid timeline. By the 2014–2015 school year, just two years after implementation of the last updates to nutrition standards began, more than 90 percent of public schools nationwide were in compliance. Research cited above confirmed that it was possible for schools to implement the updates in ways that supported health and racial equity, as well, ensuring that all students benefited from the improvements. Moreover, a recent study showed that even while dealing with challenges presented by the pandemic, most schools were still able to implement nutrition standards, including being at or very close to the current sodium targets. Updating the standards on a faster timeline would help schools build on that progress.

In addition, research has shown that there are steps USDA can take to make the proposed updates successful, including on a shorter timeline:

• Ensure schools and districts have adequate training and technical assistance, consistent messaging, and access to updated school kitchen equipment. Training and technical assistance are particularly important when school meal nutrition standards are changed. Regional “Team Up” trainings and “What’s Shaking?” resources were successful past USDA initiatives that could be reinstated and modified to align with new school meal standards.
• Reevaluate and regularly increase meal reimbursement rates, taking into account inflation, supply chain issues, and other challenges schools experience, to allow school food directors the ability to successfully order and procure foods and beverages that are healthy and appealing to students, while being able to train and retain skilled staff. Schools received a higher reimbursement rate during the COVID-19 pandemic through waivers. The waivers have since ended, resulting in a drop in reimbursement rates, although schools are still facing many of the same challenges experienced during the pandemic.
• Engage with industry providers to ensure that palatable products are made available that meet these standards and are affordable at the available reimbursement rates.
• Monitor and evaluate the impact of these updates on school revenue, policies, operations, and student outcomes.

Going Further: Expand Access to Free School Meals to All Students

When pandemic-era waivers made school meals free to all students, an additional 10 million children had access to healthy meals at no charge. Since the expiration of universal free meals at the start of the current school year, school meal debt has increased significantly while participation in school meals programs has declined.

USDA should prioritize strategies that improve access to school meals for all students. RWJF has proposed two solutions for accomplishing this: by making healthy school meals for all children permanent and by expanding the Community Eligibility Provision. We applaud USDA for proposing the latter in RIN 0584–AE93, Child Nutrition Programs: Community Eligibility Provision-Increasing Options for Schools; FNS-2022-0044. Recent research has demonstrated the benefits of offering free school meals to all students. Offering free meals to every student advances health equity by reducing food insecurity, increasing school meal participation, improving diet quality, reducing stigma, boosting academic achievement and school attendance, and supporting lower-income school districts.

Providing free, healthy school meals to all students would help the 2023 Proposed Rule benefit millions more students and families and further advance health equity. Additional research supporting this recommendation is available in our April 2022 issue brief, “Healthy School Meals for All.”

Conclusion

Thank you for the opportunity to comment on the proposed rule to update school food nutrition standards. We have included numerous citations to supporting research through direct links to the research. We direct USDA to each of the materials we have cited and made available through active links, and we request that the full text of each of the studies and articles cited, along with the full text of our comment, be considered part of the formal administrative record for purposes of the Administrative Procedure Act. If USDA is not planning to consider these materials part of the record as we have requested here, we ask that you notify and provide us an opportunity to submit copies of the studies and articles into the record.

We look forward to continuing to work with USDA and other partners to ensure that every child has the opportunity to live the healthiest life possible.

About the Robert Wood Johnson Foundation

The Robert Wood Johnson Foundation (RWJF) is committed to improving health and health equity in the United States. In partnership with others, we are working to develop a Culture of Health rooted in equity that provides every individual with a fair and just opportunity to thrive, no matter who they are, where they live, or how much money they have.

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