National Center for Health Research: April 22, 2020
National Center for Health Research’s Public Comments on Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs
[FNS-2019-0007]
We are pleased to have the opportunity to express our views on the Food and Nutrition Service’s proposed rule changes to the requirements for the National School Lunch and School Breakfast Programs. The National Center for Health Research is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with particular focus on which strategies, treatments, and policies are most effective. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
The recently proposed changes would drastically weaken school nutrition by creating large loopholes in school nutrition requirements. Despite claiming that the goal is to offer “greater ability to offer wholesome, nutritious, and appealing meals to students,” the result of these guidelines would be to seriously harm children’s access to healthy food options. Therefore, we strongly disagree with the proposed changes to school nutrition requirements.
The proposed changes are framed as providing more “flexibility” and choice to students and schools. However, these proposed changes would allow potatoes to be categorized as a vegetable despite their low nutritional value, lower the requirements for red and orange vegetables, allow grain-based desserts to meet nutritional requirements, and reduce the serving size of fruit required at breakfast.
Practically speaking, this would mean that students have fewer healthy food options to choose from, leading to poorer nutrition for students. For example, instead of red and orange vegetables such as carrots or squash for lunch, students would be able to choose French fries or tater tots. They would also be able to choose fried hash browns instead of fruit at breakfast. Children and adults enjoy fried potatoes and other potato-based foods, but they have little nutritional value and also increase sodium intake and consumption of fried foods, both of which are harmful to health. In addition, the proposed changes to the requirements for food sold a la carte would allow students to purchase unhealthy foods such as pizza every day of the week.
Prior to the current standards for National School lunch programs, we observed children whose daily lunches consisted of French fries, potato chips, and muffins or dessert. These choices were made possible by a la carte flexibility and were not unique to low-income children; they were also popular with middle-class and affluent children. Children know what foods they like, but they often avoid foods that are unfamiliar and they don’t make the best nutritional choices. Research shows that children exposed to new vegetables and vegetables that look appetizing or are described in appetizing ways will learn to enjoy those foods. But if given the choice, French fries will usually beat out healthier vegetable choices.
As we have learned too well during the current pandemic, school meals are an essential source of nutrition for thousands of American children every day. Adding more “flexibility” to school children’s food choices in the ways offered in the revised guidelines is harmful to all children and especially harms the health of children who do not have healthy meals at home. Replacing nutrient-rich foods with foods with little nutritional value or negative nutritional value (such as fried foods, pasta made of vegetables, and foods high in sodium, carbohydrates, sugar, and fat) would be very harmful, contributing to our nation’s obesity epidemic and setting the stage for children to become obese adults with diabetes and other serious health problems. We strongly urge you to reverse the proposed changes.
The National Center for Health Research can be reached at info@center4research.org or at (202) 223-4000.