From NFSN Co-Executive Directors Jessica Gudmunson and Miguel Villarreal:

“We are thrilled that the United States Department of Agriculture Food and Nutrition Service (USDA) has made a groundbreaking decision to implement the proposed rule change to expand the Community Eligibility Provision (CEP), which provides funding to allow eligible school districts to serve free school meals to all students. Previously, schools qualified for CEP if at least 40% of students identified as low-income (for example, if they are enrolled in SNAP, or the Supplemental Nutrition Assistance Program). The rule change will now lower the threshold to 25%, expanding access to free school lunches. According to the Food Research & Action Center, this pivotal decision will provide 9 million students with increased access to nutritious school meals, ensuring they have the fuel to succeed academically and beyond."

"The expansion of the CEP program will lower the threshold for school eligibility, empowering more schools across the nation to serve free, wholesome meals to their students. For the many schools serving local foods, the increased participation in school meals means that benefits of farm to school will ripple out to more students and local farmers alike. The expansion will also make statewide universal meal policies more appealing to state governments by streamlining paperwork and reducing the overall cost of universal meals programs with increased federal reimbursement for school meals.” 

“By prioritizing the health and well-being of our youth, the USDA's decision demonstrates a commitment to fighting hunger and promoting equity in educational environments." 

"We express our heartfelt gratitude to everyone who participated in the public comment period, advocating for this transformative change. Together, our voices were instrumental in shaping this outcome, and now we will work together to implement the expanded CEP program. This is a momentous victory for the health and future of our children. Together, we will continue striving to ensure that every student has the opportunity to thrive in a nurturing, equal, and food-secure environment."

About National Farm to School Network

National Farm to School Network is the leading voice for the U.S. farm to school and farm to early care and education movement, working as an information, advocacy and networking hub for communities to bring local food sourcing, gardens, and food and agriculture education into schools and early care and education settings. Learn more at farmtoschool.org.

National Farm to School Network (NFSN) is proud to announce its policy priorities for the upcoming 2023 Farm Bill. The House Committee on Agriculture is taking public input on the Farm Bill through June 9, 2023.

Karen Spangler, Director of Policy at NFSN said: “Rather than annual budget uncertainty, the Farm Bill offers an opportunity to solidify funding for the kind of long-term food system that America needs. The Farm Bill, a package of federal legislation renewed by Congress every five years, sets agriculture and food assistance policies that touch every aspect of farm to school and early care activity. But we know that this is just one piece of change needed for a truly just food system. We need to shift the economic, cultural, and decision-making power governing our food system.”

Representing organizations across all 50 states, Washington, D.C., the U.S. Territories, and Native nations, NFSN is dedicated to creating a strong and just food system for all through farm to school activities in schools and early care and education (ECE) settings.

In the Fall of 2020, NFSN released a Call to Action for a racially just food system, guiding all aspects of our work, from policy advocacy to resource design and partnership cultivation. The 2023 Farm Bill offers an opportunity to put these values into action through coordinated advocacy efforts.

NFSN's 2023 Farm Bill Priorities are based on six shared community values: economic and environmental justice, health, racial equity, workers’ rights, and animal welfare. These priorities include:

1.  Build on Ten Years of Success in Farm to School: Expand and improve the successful Farm to School Grant Program to ensure more communities have access to support for farm to school activities. Incorporate measures from the Farm to School Act, such as ensuring a mandatory budget of $15 million per year, raising the grant cap to $500,000 for projects that need it, and reducing barriers to Farm to School Grants.

2. Support Farm to School and Farm to ECE in Agriculture and Nutrition Programs: Maintain or expand the budget of SNAP-Ed to support farm to school and farm to ECE work. Encourage culturally responsive and racially equitable approaches to nutrition education. Maintain or expand support for Specialty Crop Block Grants to increase farm to school market access for specialty crop producers.

3. Support Opportunity in Local Food Systems: Increase investment in local food infrastructure and ensure market opportunities are available to all producers. Focus on refining successful programs based on producer and stakeholder feedback and expanding investments. Direct USDA to center small- and mid-sized producers, particularly producers of color, in their own purchasing programs.

4. Ensure Equity and Resilience in Agriculture and Nutrition as a Whole: Address historic and ongoing barriers to racial equity in agricultural production. Invest in opportunities for land access, land ownership, and tenure for communities of color, and support technical assistance, research, and outreach through funding to Historically Black Colleges and Universities (HBCUs) and Tribal colleges and universities.

NFSN seeks to ensure that the 2023 Farm Bill brings us closer to wins for all communities. We are committed to working with our partners and members to advocate for these policy changes, which will move us toward a just, equitable food system that promotes the health of all school children and benefits producers, workers, educators, and their communities.

Read more about our full Farm Bill platform at https://www.farmtoschool.org/resources-main/national-farm-to-school-networks-2023-farm-bill-policy-priorities. 

About the National Farm to School Network

The National Farm to School Network (NFSN) is a hub for networking, information, and advocacy to grow the farm to school movement, which connects students in schools and early care and education settings to healthy, local food and hands-on learning through gardening, food education, and support for local food procurement.

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By Nicole Melia and Melissa Froelich

Advocates for free breakfast for Pennsylvania school children went to the state capitol earlier this month to ask the legislature to consider a new bill for universal school meals including lunch.

What we feed our children makes a huge difference. It’s why there’s a diversity of voices speaking up. From food service directors to farmers and manufacturers. From parents to representatives of school districts. We all want to engage with legislators over the future of the way our young people eat in school.

...

Research shows that school meals provide the best diet quality of all major food sources in the United States, without disparities for those of lower household income.

It’s about more than breakfast. According to the National Farm to School Network, nine states have now enacted universal meals policies, which provide free meals to all students regardless of household income. Additionally, 16 states have enacted policies that support local food purchasing in schools, such as local food incentive programs or grants for local food procurement.

Here in Pennsylvania, we have the chance to be at the forefront of this new movement. Despite the success of the free breakfast program, there is still hunger in Pennsylvania that needs to be addressed.

Read the full article at PennLive.

National Farm to School Network is excited to announce that we have joined the National Healthy School Meals for All Coalition to call on Congress to make nationwide free school meals for all students a reality.

We know that school meals play an important role in reducing childhood hunger, supporting good nutrition, and ensuring that  students are well nourished and ready to get the most out of their school day.  

Research links participation in school meals to positive educational and health outcomes for our nation’s children. School meals are just as important to academic success as textbooks, computers, and transportation, and all children should have access to  them every school day. 

As vital as the school nutrition programs are to ensuring children’s access to healthy, nutritious meals, too many children in need  miss out on school meals because of the programs’ current structure. Many struggling families do not meet the eligibility threshold  for free meals, which requires a family of four to earn less than $37,000 annually. The current structure with some children being  offered free meals or meals at a reduced price, and others paying for their meals, also leads many children who are eligible for free  or reduced-price school meals, particularly those in middle and high school, to choose not to participate because of stigma.  

Providing free meals to all students, regardless of household income, would reduce stigma and ensure that all students have the  nutrition they need during the school day. It would ease the pressure on families’ household food budgets, allowing them to count on a nutritious school breakfast and lunch each school day to help make ends meet. It would reduce administrative work for school staff, allowing them to focus on preparing nutritious and appealing meals instead of processing paperwork. And it would eliminate  unpaid school meal fees, helping to ensure that the cafeteria is a positive place for all students and ending the financial burden that  school meal debt creates for school districts.  

Providing school meals to all students is also critical for advancing racial equity and justice, helping to ensure that Black, Indigenous, and Latinx students can access the key nutrition they need to thrive in the classroom and beyond.  

“National Farm to School Network represents organizations, professionals, and community members committed to a future where all communities hold power in a racially just food system. We support Healthy School Meals for All to ensure that no child misses the nutrition they need to learn and thrive, or experiences stigma. Our partners in the cafeterias, classrooms, gardens, and farms know that how children eat, grow, and learn about food sets them up for future health and success.”
— Miguel Villarreal, Interim Co-Executive Director

Read our full statement of support here.

[Harrisburg, PA] - On May 1, a group of school meals advocates will gather at the Pennsylvania State Capitol to call for the continuation of free breakfast for Pennsylvania school children and to urge the state to consider a new bill for universal school meals including lunch.

Pennsylvania’s farm to school grants provide funds to buy locally and build connections between children and the people who get food to the school meal table. Integrating policies that expand healthy school meals can do even more to benefit kids, farmers, and communities. National Farm to School Network’s “Who’s At The Table” campaign aims to raise awareness on the importance of school meal policies that value kids and value each person who gets it to the cafeteria table, and broaden public engagement to ensure this issue is at the top of the policy agenda.

The advocates—from food service directors to farmers, and from parents to representatives of school districts—will be available for interviews and photo opportunities between 11:00 a.m. to 1:00 pm. At the East Wing Rotunda, 500 Commonwealth Ave. Harrisburg, PA 17120.

The advocates will be citing the success of the current free breakfast program. They will also be highlighting the need for universal school meals, which would help to ensure that all students have access to healthy meals throughout the school day. Across the nation, 9 states have now enacted universal meals policies, which provide free meals to all students regardless of household income.

For more information, please contact Ryan Betz at the National Farm to School Network on 601 832 2785. Or Matt Davis Communications on 917 526 9530. 

What’s Inside? (Table of Contents)

• Summary
• What is the Community Eligibility Provision?
• Who Benefits From the Community Eligibility Provision?
• Why does this Rule Change Matter?
• How Can I Learn More and Take Action?

Summary

On March 23, 2023, the United States Department of Agriculture Food and Nutrition Service (USDA) proposed a rule change to dramatically expand child access to school meals. They propose to lower the threshold that schools have to meet to qualify for the Community Eligibility Provision (CEP), a federal program that enables eligible schools to serve free meals to all students. Currently, schools can qualify for the program if they have an Identified Student Population (ISP, definition below) of 40%. USDA wants to lower the threshold to qualify for CEP from 40% to 25%. This change will greatly increase the number of schools that are eligible for the program and increase the number of students benefiting from healthy school meals. 

National Farm to School Network is a champion of this rule change. We urge our partners to submit comments to the USDA in support of expanding access to CEP.

Comments are due May 8, 2023. Continue reading for more information on the proposed change, why it is important, and how to take action. 

What is the Community Eligibility Provision?

When did CEP start?

• The Healthy, Hunger-Free Kids Act of 2010 introduced CEP as a new federal program to expand access to school meals. 

Who benefits from this program?

• One in three schools participated in CEP in the 2021-22 school year, according to a report by the Food Research and Action Center. This amounts to over 33,000 schools, which represent 16.2 million students, or nearly a quarter (22%) of all children under 18 in the US. Most eligible schools (74.3%) participate in CEP.

Who can qualify for CEP?

• To be eligible to operate CEP, a school within a district must have an Identified Student Percentage (ISP) of 40% or higher. Schools can also form groups to increase their ISP and maximize federal funding. 

What is an Identified Student Percentage?

• The “identified student percentage” (ISP) is calculated by dividing the total number of identified students by the total number of enrolled students. “Identified students” are students who are categorically eligible for free meals without the need for a household income application. For example, students are considered categorically eligible if they are enrolled in Head Start or Early Head Start, the Supplemental Nutrition Assistance Program (SNAP, formerly known as food stamps), and other similar federal assistance programs, or are homeless, migrant, runaway, or are in foster care. Additionally, the USDA began a pilot program in 14 states to directly certify students if they are enrolled in Medicaid. 

How are schools funded through CEP?‍

• Schools are reimbursed using a formula that multiplies Identified Student Population by 1.6. This number will give schools the percentage of meals they serve that are fully reimbursed by the federal government. For example, a school with an ISP of 56% will be federally reimbursed for 93% of the meals they serve. The remainder of funding would have to come from non-federal sources. A school with an ISP of 63% will be reimbursed for all meals they serve by the federal government. So among schools that participate in CEP, those with higher ISPs will be reimbursed for a higher percentage of meals served. 

Who Benefits from the Community Eligibility Provision?

During the COVID-19 pandemic, the federal government made all school meals temporarily free to students. The nation was able to see first-hand the difference this support made in communities. Providing healthy school meals for all through CEP provides similar benefits throughout the school community, backed up by a robust and growing body of research evidence. NFSN has created a 3-page list of talking points that stem from this research in the context of this proposed rule change. 

It benefits students:

• It promotes equity. More students have access to healthy school meals, regardless of income.
• Without cash registers, there are shorter lunch lines and more time to eat lunch.
• There is no stigma associated with eating school lunch.
• We know hungry students can’t learn. School meals for all improve student outcomes by ensuring kids can stay focused in the classroom.

It benefits parents:

• Parents experience less stress when they don’t need to worry about preparing school lunches or paying for meals at school 

It benefits school nutrition professionals.

• There is less administrative burden for schools, which do not have to process school meal applications if they participate in CEP. 
• There are fewer reporting requirements for schools, which previously had to track each meal by payment category (such as free, reduced-price, or paid meals).
• Schools no longer have to act as debt collectors. They do not need to call parents to make up for unpaid meals. This has become a growing problem, especially after the COVID-19 pandemic.
• The lunch line is faster, without the need to collect payment from students.
• Reduced administrative burden means that more time can be spent on scratch cooking and purchasing local ingredients.

Why does this Rule Change Matter?

It will increase the number of students benefiting from healthy school meals.

More schools can participate: This rule change will lower the threshold to participate in CEP from 40% to 25%, meaning that many more schools (and more students) will be able to benefit from this program. According to Food Research and Action Center, this change will expand CEP to reach an additional 9 million students in 20,000 more schools that would now be eligible for the program. Some states even require schools to participate in all federal food assistance programs in which they qualify, which ensures more schools will benefit from CEP.

Student meal participation increases with universal access: Meal participation increases when students have access to healthy school meals. 

It will make statewide universal meal policies more appealing to state governments. 

National Farm to School Network has launched the Who’s At the Table? School Meals campaign to promote state-level universal meals policies that align with our community values. This proposed rule would support states that have implemented universal meals and make universal meals policies more appealing to state governments looking to establish universal meals. 

Most universal meals policies require their state governments to cover the difference between the regular price of the meal and any federal funding support for school meals. For example, if a meal costs $3, and the federal government already provides $1 in reimbursement for that meal, currently the state government would provide the remaining $2. This ultimately makes school meals free to all public school students.

Even in states with universal free meals policies, schools are experiencing challenges with collecting income eligibility forms needed to obtain the maximum amount of funding available from federal sources. Lowering the CEP eligibility threshold would allow more schools to participate in CEP, allowing for a more streamlined paperwork process for schools in these states, and reducing the overall cost of a program. This proposed rule change may be the catalyst for more states to adopt healthy school meals for all.

How Can I Learn More and Take Action?

To Learn More:

• Comment Request: Proposed Rule by USDA
• Summary of Proposed Rule by USDA
• Webinar on Proposed Rule by USDA
• Community Eligibility Provision Resource Center
• CEP Benefits Students and Schools web page, by No Kid Hungry
• Community Eligibility: The Key to Hunger-Free Schools School Year 2021–2022 report by Food Research and Action Center

To Get Involved:

• Read NFSN’s comment on the CEP change
• Check out NFSN’s CEP Talking Points for ideas on how you can frame your support
• Review NFSN's CEP Advocacy Toolkit

Are you ready to make a comment of your own?

• Use NFSN’s model comment document and customize it with your own experiences and values
• Submit your comment through NFSN’s Voter Voice platform.

By Trisha Bautista Larson, MPH, Program Manager and Karen Spangler, MPP, Policy Director

The public health community has long referred to the Center for Disease Control and Prevention (CDC’s) Framework for Program Evaluation as a tool to enhance and disseminate public health strategies. Twenty-five years after its creation, the CDC recently announced it would update the framework and called for comments. National Farm to School Network (NFSN) understands that evaluation is an integral part of program and policy development, implementation, and sustainability – and when conducted with equity in mind, it has the power to cultivate community empowerment. As part of our commitment to our Call to Action, we have submitted comments to the CDC urging for racial and social equity principles to be embedded in the new iteration of the evaluation framework. This is a remarkable opportunity to confront the structural racism in program and policy research and analysis, which have been rooted in extracting information from communities, to one that reimagines the way findings are shared and increases stakeholder accountability.

CDC’s Evaluation Framework Update Should Include:

• Systems Thinking - Provide tools that support a more complex view of program impact and reflect advances in public health research. Farm to school and farm to early care education practitioners see every day that health is shaped by more than just individual behavioral interventions. Thus, the new Framework should take into consideration the complexity of translating programs and policy recommendations into real world applications. Explicitly including approaches such as the Policy, Systems, and Environmental change allows for crucial flexibility in adapting “best practices” for program and policy implementation at the community and individual levels. Integrating PSE approaches in the new Framework can help bridge the complex intersection of inter/intrapersonal relationships, community, and other social factors with knowledge, behavior, and ultimately, long-term health outcomes for program and policy implementation. 
• Asset-based Approach and Lived Experiences - Consider the lived experiences and knowledge that already exist in the communities intended to be served even prior to introduction to a new program or policy initiative. Proactively working to engage those who are directly impacted by health inequities can bolster the ability to make long-term change beyond a specific program or policy intervention. 
• Collaboration - Ensure that evaluation design and evidence gathering are not extractive of communities. The new Framework should seek to embed and build upon Community-Based Participatory Research methods. Approaches like these foster equitable relationships between researchers/practitioners and community stakeholders to cultivate a space that centers mutuality and community empowerment. The new Framework should also be able to set fresher standards on ways to equitably communicate and distill research findings.

For additional information and framework around centering racial and social equity in farm to school evaluation, please visit NFSN’s Racial and Social Equity Assessment Tool for Farm to School Programs and Policy. This tool was developed in consultation with NFSN Partner organizations that are deeply rooted in embedding health equity in their work. 

We are thankful for the opportunity to offer this perspective to the CDC as they craft the next iteration of the framework for program evaluation. This is an essential time for agencies to be investigating the way in which practitioners – much like in the public health community – evaluate and communicate research findings that aim to impact health outcomes.

What’s Inside? (Table of Contents)

• Intro
• What are “Rules” vs. “Laws” in General? Why is it Important to Advocate?
• What are the Child Nutrition Program Rules and Why are They Important?
• Rule Change Highlights
• How Can I Learn More and Take Action?

On February 7, 2023, the US Department of Agriculture (USDA) announced proposed rule changes to its child nutrition program standards. This will have a huge impact on school, after-school, and early child care meal programs. Before implementing these proposed changes, USDA is asking individuals and organizations to share feedback on how these changes would affect people and what to keep in mind when implementing.

The proposed rule changes include the following:

• Expansion of local purchasing (a.k.a. “Geographic Preference”)
• School nutrition standards, including added sugars, milk, grains, and sodium
• Changes in professional standards for school nutrition careers 
• Increased focus on traditional foods and menu planning for American Indian and Alaskan Native students
• Increase in Buy American policies
• And more

National Farm to School Network (NFSN) is excited that a number of our longtime policy priorities were adopted in these proposed rule changes, including buying local, strides in equity, and better career access.

More work is needed to make sure the most helpful rule change proposals become officially adopted. NFSN conducted a series of listening sessions and a survey from partners to put together and submit comments on behalf of the network. At the same time, we want to encourage YOU and your organization to consider submitting comments individually so that USDA can hear from a variety of relevant voices.

NFSN is invested in lifting the voices of people directly involved with school meals and other child nutrition programs because some of these changes, if done right, can help change these programs so their decision-making can be less focused on the bottom dollar and more based on values that better serve their students and communities.

A question we want you to consider as you advocate submit comments: How can USDA’s rules be implemented in ways that help make your values-based decisions more feasible?

Comments are due May 10, 2023. Continue reading for more information on the proposed changes, why they’re important, and how you can take action.

What are “Rules” vs. “Laws” in General? Why is it Important to Advocate?

Many people are aware about voting during election season. We vote for certain laws, and we vote for the individuals to represent us, including federal (Senators, House Representatives, and presidents) and state representatives (Senators, House Reps, and governors), plus other representatives like city council members, school board members, etc.

After being elected, our representatives propose bills and vote to pass them into law. This includes the Farm Bill and Child Nutrition Reauthorization, which NFSN does a lot of advocacy around. It’s easy to forget about this part of advocacy. Some may say things like, “we already voted for them, so there’s nothing we can do.” However, it’s just as important to tell our representatives how we want to be represented once they enter office.

After a law is passed, it’s then the responsibility of the different departments like USDA to take those laws and put them into action. Bills are often written with a degree of vagueness, and they can be open to interpretation on how the actual processes and logistics will go. This is called rule-making. This is yet another stage in the policy process where advocacy can come into play. It’s important to advocate for rules like the Child Nutrition Program rules to make sure they are implemented in ways that help the people affected.

‍What are the Child Nutrition Program Rules and Why are They Important?

In 1980, the federal government released the first Dietary Guidelines for Americans (DGA). It was then established that USDA’s child nutrition programs must align with the up-to-date scientific evidence on a healthy diet set forth in the guidelines. USDA translates these high-level guidelines into specific rules for things like sodium levels or servings of vegetables. The standards are also important because they set rules for other aspects of how federal program funds are used, such as purchasing products.These rules directly affect school, after-school, and early care meals (as well as adult care food programs).

The current rules that are in place through the next school year were issued in 2022 as a temporary, transitional policy. The new proposed rules are called “durable rules,” meaning they will remain in place permanently until the next DGA update, which happens every five years.  However, it’s very possible that they will remain in place for an even longer time period if the DGA do not dramatically change.

Rule Change Highlights

‍NOTE: This is a simplified version of the changes. For fuller details, see “How Can I Learn More and Take Action” below.

Geographic Preference Expansion (i.e. Local Purchasing)

This rule change would simplify and expand local purchasing guidelines for schools. Current rules allow local purchasing as one of many factors schools can use to award a food vendor in a competitive bid. This rule change would allow child nutrition program operators to consider “local” a necessary factor that vendors must meet in a competitive bid.

NFSN strongly supports this rule change as complex purchasing policies for school meals are one of the biggest barriers for schools and early care and education sites to work with local, beginning, and small producers. This rule change would support local farmers and economies as well as help schools serve more fresh, local foods to students.

School Nutrition Standards

USDA sets specific standards that all child nutrition program operators must comply with and document in order to receive reimbursement for meals. These include the following:

• Added Sugars: The proposed rule would create a limit on added sugars in all child nutrition programs (school breakfast, school lunch, and the Child and Adult Care Food Program, or CACFP). A product-based limit would begin in School Year 2024-2025 for grain-based desserts, breakfast cereals, yogurt, and flavored milk (see the proposed limits on grams of added sugar for each product here). This would replace the current weekly maximum limit that is in place for CACFP. Beginning in SY27-28, there would be an additional limit to ensure that, on average throughout the week, no more than 10 percent of calories per meal are coming from added sugars. “Added sugars” means products like cane or beet sugar, corn syrup, honey, maple syrup or agave, or other sweetener products containing calories. The proposed rule does not contain specifics about artificial sweeteners or products like stevia but commenters are encouraged to share their views with USDA. 
• Milk: Current standards allow low-fat or fat-free flavored milk (such as chocolate milk) for all K-12 grade levels, in addition to unflavored milk. The proposed rule asks whether flavored milk should be limited to Grades 9-12, Grades 6-12, or allowed for all grades as it is currently.  
• Sodium: The proposed rule would replace the current sodium targets with phased-in reductions. School breakfast would have a 10% reduction in the sodium limit in SY5-26, and another 10% reduction beginning SY2027. School lunch would have 10% reductions in SY25, SY27, and SY29. You can see the numeric limits for each phase and age group here.
• Whole Grains: The current standards require 80% of products each week to be “whole grain rich.” The proposed rule asks for input on whether to keep the current standard or update to a requirement that all grains meet the whole grain-rich requirement, with the exception that enriched grains may be offered one day each school week.
• Substituting Vegetables for Fruits at Breakfast: The proposed rule would allow providers to substitute vegetables for fruits in breakfast (such as potatoes) if the menu includes other “vegetable subgroups” (such as  leafy greens or carrots) on the other days. You can see the full breakfast Meal Pattern here for further details.
• Nuts and Seeds: Currently, nuts and seeds can only count toward 50% of the “meat/meat alternate” requirement for a reimbursable meal, and must be accompanied by another protein food (such as cheese). The proposed rule would allow nuts and seeds to fully count toward the “meat/meat alternate” requirement, and renames the category to “proteins” for better clarity in meal planning.
• NSLP Afterschool Snacks: The NSLP Afterschool Snacks program standards would now align with the CACFP snack standards. This change would require NSLP afterschool snack to contain at least two out of five component categories (milk, vegetables, fruits, grains, or meat/meat alternate). 
• Competitive Foods: The rule keeps standards for calories, sodium, fats, and total sugars in USDA-designated “Smart Snacks,” and adds an exemption for hummus that allows it to be sold as a Smart Snack.

USDA is seeking feedback from the public and communities involved in administering or using these programs. 

Traditional Foods and Menu Planning Options

The rule changes include three specific regulations on traditional foods and menu planning:

• It explicitly clarifies that traditional foods may be served as part of a reimbursable school meal
• It establishes that the definition of “traditional foods” refers to a “food that has traditionally been prepared and consumed by an [American] Indian Tribe,” per the Agriculture Improvement Act of 2014
• It expands the ability to substitute vegetables for grains in Tribally operated schools, schools operated by the Bureau of Indian Education, and schools serving primarily American Indian or Alaska Native children

This rule change could be one step in building a more inclusive school that supports students eating foods reflecting their cultures and supports the farmers that grow those foods. This supports NFSN’s Call to Action, that 100% of communities will hold power in a racially just food system. USDA is asking stakeholders whether this definition of “traditional foods” is the appropriate one. Additionally, USDA requests public input on additional menu planning options that would improve the child nutrition programs for American Indian and Alaska Native children. This is an excellent opportunity to elevate the needs and barriers facing child nutrition providers as they try to plan meals and purchase products that celebrate students’ cultures. 

‍Buy American

Currently, schools are encouraged to buy American but may be exempted when products aren’t easily sourced in the U.S. or there is a significant price difference. However, these exemptions are currently not defined nor documented. This rule change would set a 5% cap on total annual commercial food costs of non-domestic foods, and clarify that over 51% of a food product must consist of agricultural commodities that were grown domestically to count as a “domestic product.” Child nutrition program operators would be required to document their non-domestic food purchases as well as require “Buy American” provisions to be part of a food vendor’s contract.

This approach would dramatically improve USDA’s ability to understand the gaps and market opportunities in the school food value chain, but of course any additional documentation and compliance measures could be burdensome for school nutrition professionals. USDA wants to understand if this approach to limits and documentation will help meet the goal of supporting domestic producers and workers, who risk being undercut by cheaper competition, and supporting school nutrition professionals who may struggle with budget and product availability constraints.

Professional Standards

USDA aims to ease difficulties in hiring and increase professional career pathways in school nutrition. Current Professional Standards for medium and large districts participating in federal child nutrition programs require a degree. The proposed rule would allow medium and large school food authorities to substitute 10 years of school nutrition program experience for a bachelor’s or associate’s degree.

This rule change could remove unnecessary barriers to professional advancement for experienced child nutrition professionals. USDA is especially looking to hear from school nutrition professionals about the possible consequences of this change to make sure they implement this in a way that’s as helpful as possible.

How Can I Learn More and Take Action?

Read about the proposed rule changes and take note of what most directly affects you and your community:‍

• Comparison chart summarizing proposed rule changes
• Proposed Implementation Timelines‍
• ‍Proposed changes specifically for school nutrition standards‍
• Full proposed changes

Check out these additional resources from NFSN: 

• NFSN's organizational comment letter ‍
• Detailed model comment
• Advocacy Toolkit

After you determine which topics to focus on, read USDA’s specific questions for which they are seeking answers.

After you have written down your answers to USDA’s questions, submit your comments (click for instructions). Public comments must be submitted by May 10, 2023.

• NFSN has also created a Voter Voice Campaign with a link you can submit comments to: click here to view and send the sample message.
• As these are public, submitting comments are not typically considered lobbying.

USDA has identified its specific questions, as well as created the resources/charts in the document above, to help simplify the process for members of the public, and we applaud this step to help people share their values and engage with USDA.

Let’s take action together and make sure our kids and communities are supported.

If you have any questions about the proposed rule changes, contact Karen Spangler at karen@farmtoschool.org