NCHR Comments On Transitional Standards for Milk, Whole Grains, and Sodium

March 24, 2022


National Center for Health Research’s Comments on United States Department of Agriculture’s Transitional Standards for Milk, Whole Grains, and Sodium

We are writing to express our views on the United States Department of Agriculture’s (USDA) Transitional Standards for Milk, Whole Grains, and Sodium in the Child Nutrition Programs.

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which strategies and treatments are most effective for consumers. We do not accept funding from companies and organizations related to the proposed standards, so we have no conflicts of interest.

Nutrition standards that ensure that children receive healthy food alternatives in their school meals are of utmost importance. For this reason, we agree that USDA’s proposed transition standards, which will reduce sodium and increase whole grains, are a much-needed improvement to Child Nutrition Programs. We also urge USDA to ensure that the nutrition standards for school meals closely follow the 2020-2025 Dietary Guidelines for Americans, which emphasize healthy meal patterns with nutrient-dense foods. Following these guidelines, school meals should include no more than 10% of daily calories from added sugar. In addition, we endorse USDA’s prioritization of parent and stakeholder input to create a comprehensive revision of the standards to be implemented in the school year 2024-2025.

School meals play a critical role in addressing food insecurity, nutrition, and well-being among families. The provision of school meals through the Healthy Hunger-Free Kids Act has been integral in securing children’s health and for the prevention of diet-related chronic diseases.

We agree with the USDA that COVID-19 pandemic-related changes to school meal standards, which included broad flexibility to support families in need, needs to be revised in order to provide healthier meals. USDA should also keep in mind that the increased rates of food insecurity brought on by the pandemic have increased childhood hunger and obesity, especially among Black and Latinx children.

For this reason, we urge USDA to implement several technical assistance programs to ensure that children benefit from the nutrition improvements provided by school meals:

  • Increasing access to meals, for example though strategies such as innovative school breakfast programs
  • Giving children at least 30 minutes for lunch. To avoid children rushing their lunch, we recommend that lunch not be immediately followed by recess
  • Extending eligibility criteria to increase access to school meals to help improve the health and well-being of children who have limited access to nutritious food at home.

The National Center for Health Research can be reached at info@center4research.org or at (202) 223-4000.