VRG sent in the following testimony to the USDA concerning school food lunch (comments are due April 22, 2020):

We welcome the opportunity to comment on Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs. 

More than 30 million children in the United States participate in the National School Lunch Program yearly and more than 14 million children participate in the School Breakfast Program (2). These programs are federally funded, operate in public and nonprofit private schools, and have a stated goal of providing nutritionally balanced, low-cost or no-cost breakfasts and lunches to children each school day (1,2). 

Children get more than half of their daily calories from school meals so it’s important that these meals provide nutritious food, including whole grains, beans, vegetables, and fruit.

Changes to school meal requirements that were implemented in school year 2012-2013 resulted in significant improvements in the nutritional quality of school meals (3). Specifically, more whole grains, greens, and beans were served to children at lunch and more whole grains and fruit were served at breakfast (3).

The changes proposed by Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs would eliminate many of the program improvements that were made in 2012-2013. The proposed changes would reduce the amount of vegetables and fruit required to be served at breakfast and lunch. Fewer red and orange vegetables (sources of vitamin A) would be required to be served at lunch. The proposed change would allow pasta made with vegetable flour to be counted as a serving of vegetables. We do not support these changes. It is important for children to have an opportunity to choose a variety of vegetables and fruits and to become familiar with vegetables that are presented as vegetables.

If breakfast is served outside of the cafeteria, which many school districts do, the amount of fruit included would be cut from one cup to a half cup. Since the number of calories that must be served at breakfast is unchanged, a half cup of fruit could be replaced with cheaper food like sweet pastries. The proposed changes would allow schools to offer potatoes as a vegetable every day. Potatoes could take the place of fruit at breakfast. Potatoes are a fine food, but they don’t supply the generous amounts of vitamin C, vitamin A, calcium, and iron that other vegetables or fruits do.

A rationale given for the changes is that children don’t like the changes that were made in 2012-2013 and that they’ve resulted in more waste. A study conducted by USDA, refutes this argument and shows that after the 2012-2013 changes, there was either less plate waste or about the same plate waste as before (3). We do not support the proposed changes to reduce fruit servings for breakfast served outside of the cafeteria or allowing potatoes to be served as a vegetable daily.

For many children, school meals are an opportunity to have access to healthy food. These proposed changes cut plant foods from school meals and are harmful to children’s nutrition.

Thank you for the opportunity to comment on this issue.

References
1. USDA. The National School Lunch Program. 2017. https://fns-prod.azureedge.net/sites/default/files/resource-files/NSLPFactSheet.pdf
2. USDA. The School Breakfast Program. 2017.  https://fns-prod.azureedge.net/sites/default/files/resource-files/SBPfactsheet.pdf
3. USDA. School Nutrition and Meal Cost Study. 2019. https://fns-prod.azureedge.net/sites/default/files/resource-files/SNMCS_Summary-Findings.pdf

To submit your own testimony by April 22nd, go here.
https://www.federalregister.gov/documents/2020/03/23/2020-05979/simplifying-meal-service-and-monitoring-requirements-in-the-national-school-lunch-and-school