Research shows school meals support academic achievement, obesity prevention and overall student health by improving children’s diets and combatting hunger. School meals are as critical to learning as teachers and textbooks. School Nutrition Association (SNA) has long supported offering healthy school meals to all students at no charge, as an integral part of their education. On behalf of school nutrition professionals and the students they serve, SNA calls on Congress to work toward this long-term goal by preserving the Community Eligibility Provision (CEP) and taking the following additional steps:

Increase Student Access to School Breakfast and Lunch

Eliminate the Reduced Price Category (ERP)

Students whose families earn between 130 and 185 percent of the federal poverty level qualify to receive reduced price meals. However, some of these students go hungry during the school day or accumulate unpaid meal debt because many families struggle to afford the reduced price co-pay. Allowing these vulnerable children to receive free school meals will ensure consistent access to the nutrition they need to succeed, while reducing growing unpaid student meal debt and easing administrative burdens.

Research shows school meals support academic achievement, obesity prevention and overall student health and well-being by improving children’s diets and combatting hunger. In an effort to ensure all students have access to the nutrition they need to succeed, Congress provides free or reduced price school meals to income eligible families.

Students qualify for reduced price school meals if their families earn between 130 and 185 percent of the federal poverty level (between $33,475 and $47,638 for a family of four in School Year 2019/20). Unfortunately, many of these students go hungry during the school day when their families cannot afford the reduced price co-pay.

More than 936,000 students approved for reduced price school lunches did not receive them on the average school day in Fiscal Year 2019, according to an analysis using USDA administrative data.1

These children already face an increased risk of food insecurity, when “access to adequate food is limited by a lack of money and other resources.” Among U.S. households with children, 31 percent of those earning less than 185 percent of the poverty level (the threshold for reduced price meal eligibility) were food insecure (Household Food Security in the United States in 2018).

For families with multiple school-aged children who are struggling to make ends meet, the 30 cents per breakfast and 40 cents per lunch reduced price co-pay can quickly add up, forcing parents to make tough decisions about whether their children will receive nutritious school meals. By providing free meals to reduced price eligible students, Congress can ensure vulnerable students in these food insecure homes do not go hungry during the school day. Eliminating the Reduced Price category (ERP) will bring the free school meal income eligibility limits in line with those of the Women, Infants and Children (WIC) program, ensuring needy children have consistent access to well-balanced school meals.

ERP will also reduce growing unpaid meal debt for schools that serve students who are unable to pay for their meals. SNA’s 2019 School Nutrition Trends Report found that 75% of responding school districts had unpaid student meal debt at the end of the 2017/18 school year and the median amount of debt reported by districts has increased substantially.

Instead of investing time and resources into collecting co-payments from reduced price eligible students and ensuring delinquent accounts are repaid, school nutrition staff can focus on serving students and improving school menus. Furthermore, ERP will help streamline administrative counting, claiming and meal eligibility procedures for overburdened school nutrition staff.

1 This figure does not include students attending schools that participate in the Community Eligibility Provision (CEP). CEP schools serve meals at no charge to all students without an application. Meals served are claimed in either the free or paid categories; CEP schools do not track reduced price eligibility.

Expand Direct Certification with Medicaid for Free and Reduced Price Meals (DCM-F/RP) to All States

Allow all states to use Medicaid data to automatically certify eligible students for free and reduced price meals. Direct certification eliminates the school meal application requirement for needy families, reduces paperwork and processing for schools, improves certification efficiency and accuracy and decreases unpaid meal debt.

Direct certification is an electronic data-matching process that automatically certifies income-eligible students to receive free or reduced price school meals without an application, based on their families’ participation in other means-tested assistance programs.

Direct certification increases efficiencies and benefits students, families and schools. The process:

  • Eliminates barriers to healthy school meals for at-risk students;
  • Spares low-income parents a cumbersome, unnecessary application process;
  • Reduces paperwork, processing and administrative costs for schools, allowing them to focus resources on serving students and improving menus; and
  • Substantially reduces school meal certification errors.

USDA cites the traditional school meal application process as “the single biggest source of improper program payments.” Direct certification has dramatically reduced errors and improper payments by replacing self-reported income information with verified sources.

Expanding direct certification processes builds on this success by supporting increased implementation of the Community Eligibility Provision (CEP), which allows high-poverty schools to offer school meals at no charge to all students without an application. School eligibility and reimbursement rates for CEP are based on the percent of students certified for free meals without an application through means-tested assistance programs. As more students in low-income communities are directly certified, more schools can participate in CEP, further reducing errors and eliminating barriers to healthy school meals.

In addition, expanding direct certification will curb the growing national problem of unpaid student meal debt. Instead of spending resources to collect delinquent meal payments from families who qualify but have not applied for free meals, school nutrition staff can remain focused on serving students nutritious meals. At-risk students will no longer need to worry about paying for school meals they are eligible to receive for free.

To build on the many successes of direct certification, the Healthy, Hunger-Free Kids Act of 2010 required USDA to conduct a demonstration adding Medicaid to the list of programs used to directly certify students. Since 2012, 19 states1 have participated in the Medicaid direct certification demonstration. An evaluation found that the demonstration “resulted in substantial numbers of students directly certified to receive free or reduced-price meals based on Medicaid data, comprising more than one-quarter of all students directly certified for free or reduced-price meals.”

Congress should ensure all states can utilize Medicaid data to directly certify students for free and reduced price school meals.

1California, Connecticut, Florida, Illinois, Indiana, Iowa, Kentucky, Massachusetts, Michigan, Nebraska, Nevada, New York, Pennsylvania, Texas, Utah, Virginia, Washington, West Virginia and Wisconsin

Urge the US Department of Agriculture (USDA) and the US Department of Education, in Collaboration with School Food Authorities (SFAs), to Develop Guidance on Ensuring Students Have Adequate Time to Eat Healthy School Meals

Short lunch periods are a concern – especially for millions of food-insecure children who depend on school meals. To increase consumption of fruits and vegetables, which take longer to consume, and to minimize food waste, schools must provide students adequate “seat time” in the cafeteria.

Short lunch periods are a concern for all students – especially millions of food-insecure children who depend on school meal programs as a primary source of key nutrients. Research demonstrates that school breakfast and lunch programs support obesity prevention, student health and academic achievement. Schools must ensure students have adequate time to consume these meals.

School meals include more fresh produce, and these high-fiber, crunchy foods take more time to eat. Short lunch periods cause many students to discard the nutrient dense fruits, vegetables and milk that they don’t have time to finish.

Research shows student consumption of school meals is “significantly associated” with the amount of time to eat. Students with shorter lunch periods were less likely to select fruit and ate less of their vegetables, milk and entrees. Researchers concluded that “school policies that encourage lunches with at least 25 minutes of seated time may reduce food waste and improve dietary intake.”

As part of their “Making Time for School Lunch” research brief, the Centers for Disease Control and Prevention (CDC) recommended that schools “ensure that students have at least 20 minutes once they are seated (seat time) to enjoy their meal and socialize.”

Any effort to address time to eat must focus on “seat time,” as lunch periods also require adequate time for students to get to the cafeteria and receive their meals. School cafeteria professionals minimize time spent in line by streamlining the serving process, offering grab-and-go options or establishing multiple points of sale, including hallway kiosks or healthy vending machines. However, in overcrowded schools or those that establish single lunch period schedules (often called “Power Hour”), school meal programs often struggle to serve students in a timely fashion. School nutrition professionals must be included in scheduling decisions to ensure students have adequate time to eat.

Strengthen School Meal Programs

Preserve USDA’s 2018 Final Rule Child Nutrition Programs: Flexibilities for Milk, Whole Grains and Sodium Requirements

This final rule preserves strong standards for school meals, including calorie and fat limits, Target 1 sodium reductions and mandates to offer students a variety of fruits, vegetables, whole grain options and low fat or fat free milk.

SNA supports maintaining robust federal nutrition standards to ensure all students receive healthy, well-balanced meals at school. The final rule on school meal flexibilities preserves strong standards, including Target 1 sodium reductions and limits on calories and fat, which ensure meals do not contribute to childhood obesity. Schools are still required to offer students a wide variety of fruits, vegetables, whole grain options and low fat or fat free milk.

Research shows school meals are healthier than the typical packed lunch, but two million fewer students eat school lunches each day since updated nutrition standards took effect. This menu planning flexibility can help entice students back into the cafeteria and eating the healthy options offered with school meals.

The December 2018 final rule made three changes to school meal standards:

  1. Whole grains: The rule restored the 2012 mandate that at least half of all grains offered with school meals be whole grain rich. Many schools struggled to meet the 2014 requirement for all whole grain rich foods. Few families or restaurants serve only whole grains, and the Dietary Guidelines allows for consumption of some refined grains. Many schools encountered strong regional and cultural preferences for specific items like flour tortillas. Allowing schools a little leeway to offer a few enriched grain options each week has not compromised whole grain successes. SNA’s 2019 School Nutrition Trends Report found 90% of school districts are exceeding the current whole grain mandate and nearly 90% are working to increase student acceptance of whole grains through one or more cited tactics, including student taste tests and the use of white wheat for a lighter, softer texture.
  2. Sodium: The final rule maintained Target 1 sodium reductions, delayed implementation of Target 2 until July 2024 and eliminated the final target. Schools significantly reduced the sodium content of school meals to meet Target 1 and are working toward Target 2 reductions. Even the Institute of Medicine warned that meeting later targets may not be possible given naturally occurring sodium in foods and other challenges (School Meals: Building Blocks for Healthy Children, 2010).
  3. Milk: The final rule allowed schools to offer flavored 1% milk. Schools must continue to meet calorie, fat and sodium limits for school meals, so any nutrient changes resulting from the addition of flavored 1% milk must be offset in other parts of the menu.

Updated nutrition standards for school meals have been a tremendous success overall, but a few overly prescriptive rules resulted in unintended consequences, including reduced student lunch participation, higher costs and food waste. The final rule has helped school menu planners manage these challenges and prepare nutritious meals that appeal to diverse student tastes.

Increase USDA Foods (Commodities) Support for the School Breakfast Program (SBP)

The FY 2020 Agriculture Appropriations Bill contains $20 million for breakfast commodities. Increasing USDA Foods support for SBP will allow more students to benefit from a nutritious school breakfast, help schools cover rising costs and advance USDA’s mission of supporting America’s farmers.

Support USDA’s Ongoing Effort to Streamline Overly Complex Child Nutrition Programs

Streamlining regulations will minimize costs, allowing school nutrition professionals to invest time and resources toward better serving students.

The overwhelming complexity of federal child nutrition program regulations and burdensome administrative requirements hinder efforts to better serve students. Streamlining regulations will minimize costs and allow school nutrition professionals to spend more time and resources in the cafeteria, interacting with students, hosting taste tests, planning nutrition education initiatives and improving menus and operations.

In January 2020, USDA released proposed regulations intended to simplify meal service and monitoring requirements in the National School Lunch and School Breakfast Programs. The School Nutrition Association’s (SNA) comments in response to the proposed rules support the recommended changes, notably:

  • A return to the 5-year Administrative Review cycle for school meal programs that consistently operate in
    compliance with federal regulations: The congressionally mandated Child Nutrition Reporting Burden Analysis
    Study recommended a risk-based review cycle to maintain accountability while reducing onerous paperwork and administrative requirements.
  • Proposals to simplify meal service: Current school meal flexibilities (see above) eased school menu planning challenges while preserving strong nutrition standards to benefit students. Likewise, this proposed rule would protect
    caps on calories and saturated fat, which ensure school meals do not contribute to obesity, and preserve Target 1 sodium reductions. The proposal would maintain daily and weekly vegetable portion sizes and mandates that schools offer a wide variety of vegetables with school meals, including weekly offerings of dark leafy greens, red/orange vegetables and legumes. Key proposed changes include:

    • Vegetable subgroups: Current subgroup requirements place a disproportionate emphasis on red/orange
      vegetables the subgroup offering the fewest choices, resulting in the same vegetables being served several times each week. This effectively limits efforts to menu more seasonal and locally grown foods and introduce students to unfamiliar vegetables. The proposed change will allow schools to offer more vegetables from the “other” category, the largest subgroup featuring a vast array of options that range from student favorites like green beans, sugar snap and snow peas, to vegetables many students haven’t been exposed to, such as avocados, squash, beets and radishes.
    • Protein at breakfast: Under current rules, a meal of scrambled eggs served with milk and fruit does not
      meet federal standards, as schools are required to offer a grain with every breakfast. With limited budgets, many schools cannot afford to offer protein rich foods in addition to the required grain each school day. By eliminating the minimum grain requirement for breakfast, the proposed rule will allow schools to offer more lean protein options, like eggs, yogurt, low fat cheese and turkey sausage, to keep students satiated throughout the morning.
    • Breakfast fruit requirements: Schools must offer students two servings (a full cup) of fruit with every breakfast. In the cafeteria, students can choose to take just one serving, but when breakfast is served in grab-and-go breakfast bags from hallway kiosks or in the classroom, students must take the full cup. Whether a student wants just a single serving or doesn’t have time to eat two servings of fruit, the requirement leads to unnecessary food waste. This proposed change would give schools struggling with excessive waste the option to serve a half cup of fruit when breakfast is offered outside of the cafeteria.
    • Substituting vegetables for fruit at breakfast: Fruit is still the popular choice for breakfast sides. However,
      schools wanting to increase variety in menu options should be allowed to substitute a vegetable on occasion, without having to serve dark leafy greens, legumes and red/orange vegetables with breakfast.
    • A la carte sales: Entrees and sides that already meet strict nutrition standards for school meals should be
      allowed for a la carte purchase any day of the week. The proposed rule would help ensure students can choose from a variety of healthy options in the cafeteria, including items like chef salads, vegetables paired with dip, deli sandwiches and soups, often prohibited under Smart Snack standards.

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