Nutrition Standards and Meal Requirements for National School Lunch and Breakfast Programs: Phase I. Proposed Approach for Recommending Revisions (2008)

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2 The Nutrition Standards and Meal Requirements: Description and Topics Relevant to Their Revision Laws and regulations establish the specifications that those schools participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) must meet to qualify for cost reimbursement from the federal government. The nutritional specifications, currently provided as Nutrition Standards and Meal Requirements, were designed to ensure nutritious meals for schoolchildren, and they have evolved over time (see Appendix B). An understanding of the current U.S. Department of Agriculture (USDA) provisions for school meals sets the stage for the consideration of recommendations for revising the current standards and requirements. This chapter outlines the Nutrition Standards, Meal Requirements, and related components of the current NSLP and SBP. The chapter also covers topics that the committee identified to be important to its considerations, many of which also were identified as critical issues by USDA (see Appendix E). CURRENT NUTRITION STANDARDS AND MEAL REQUIREMENTS The Nutrition Standards provide the foundation for the NSLP and the SBP. The related Meal Requirements facilitate the actions needed to implement the Nutrition Standards and develop menus and meals. At present, Meal Requirements reflect two sets of meal standards. The food- based menu planning (FBMP) approach focuses on the types and the amounts of foods to be offered. The second set of meal standards, the nutrient-based menu planning (NBMP) approach makes use of computer software to plan menus that meet the Nutrition Standards. Local school food authorities (SFAs) decide which menu planning approach is to be used and, hence, which set of meal standards is to be followed. The SFAs then develop their specific menus accordingly. Currently, approximately 70 percent of schools use the FBMP approach (USDA, 2007a). The Nutrition Standards and Meal Requirements (and their related sets of meal standards) are described further in sections below. To receive federal reimbursement for the meal, SFAs must first offer a meal that meets the as offered and reimbursable meal standard for the menu planning option that the school has chosen to follow. Next, the student must select the items that are consistent with the as served reimbursable meal standard. On the basis of prescribed record-keeping requirements, SFAs may claim federal reimbursement for the meal. However, the level of reimbursement depends on 35 

36 NUTRITION STANDARDS AND MEAL REQUIREMENTS whether the individual student qualifies for a full-price, reduced-price, or free meal. This is described in further detail in the “Meal Requirements” section below. Figure 2-1 identifies the standards that are the main focus of the committee’s task and illustrates their interrelationships. The task includes the specification of standards for the two types of menu planning approaches currently encompassed within the Meal Requirements (these current standards are listed in detail in Appendixes G and H). In addition, to make appropriate recommendations, the committee was asked to articulate an approach (a planning model) for the development of the Nutrition Standards that is consistent with the current Dietary Guidelines for Americans and with current applications of existing nutrient reference values. Planning Model for School Meals ---------Nutrition Standards---------- ------------------Meal Requirements------------------- (Lunch and Breakfast) (Lunch and Breakfast) Standard for Food-based Menu Planning • Food components comprising a Nutrition reimbursable meal as offered and Standards as served Key nutrients from • Amounts of food items per Nutrition Standards calculated for relevant reimbursable meal by age-grade age-grade groups groups (i.e., “nutrient standards”) Standard for Nutrient-based Menu Planning • Menu items comprising reimbursable meal as offered and as served • Five-day average for amounts of key nutrients per reimbursable meal for relevant age-grade groups (i.e., “nutrient standards”) FIGURE 2-1 Current standards for school lunch and breakfast under review by the committee. 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 37 Nutrition Standards for School Meals Description of the Current Nutrition Standards The existing Nutrition Standards (Table 2-1) were put in place in 1995 through a policy initiative and related regulation known as the School Meals Initiative (SMI) for Healthy Children (USDA, 1995). This 1995 USDA regulation requires that the meal programs comply with the then current Dietary Guidelines for Americans and that school lunches and breakfasts provide at least one-third and one-fourth of the 1989 Recommended Dietary Allowances (RDAs) (NRC, 1989) for selected nutrients, respectively, on a daily basis, as averaged over 5 consecutive school days. In addition, the program regulations specify the maximum amounts of total fat and saturated fat and the minimum number of calories. 1 Legislation passed in 1996 (Personal Responsibility and Work Opportunity Reconciliation Act of 1996, P.L. 104-193, (August 22, 1996)) mandated that school lunch and breakfast provide, on average over a 5-day week, one- third and one-fourth of the RDAs, respectively. TABLE 2-1 Current Nutrition Standards for the National School Lunch and Breakfast Programsa Nutrient Standard for the Meal School Lunch School Breakfast Key nutrients •Calories ⅓ of the REAb,c ¼ of the REAb,c c •Protein ⅓ of the RDA ¼ of the RDAc c •Calcium, iron, vitamins A and C ⅓ of the RDA ¼ of the RDAc •Total fat ≤30% of calories ≤30% of calories •Saturated fat <10% of calories <10% of calories Recommended but not required •Cholesterol and sodium Decrease levels in the meals •Dietary fiber Increase level in the meals •Grain products, vegetables, Increase levels in the meals and fruits •Eat a variety of foods a These standards apply to the average content of meals over one school week (5 days). b REA = Recommended Energy Allowance (NRC, 1989). c These reflect the minimum standard for the appropriate age-grade group. SOURCE: USDA, 1995. 1 The term “calories” is used to refer to kilocalories throughout this report. 

38 NUTRITION STANDARDS AND MEAL REQUIREMENTS In addition to calories, the existing Nutrition Standards focus on protein, calcium, iron, and vitamins A and C because of the roles that these nutrients play in promoting growth and development (USDA, 1995). These five nutrients were intended to serve as a practical proxy to ensure that school meals include other essential nutrients. The components of the Nutrition Standards that address total fats and saturated fats support the recommendations in the 1995 Dietary Guidelines for Americans (HHS/USDA, 1995), as do the recommended (but not required) levels of cholesterol, sodium, and dietary fiber. All 11 of these nutrients and other dietary components are identified on the nutrition labels of food products, providing an important source of information for school menu planners. As part of its task to recommend revisions to the Nutrition Standards, the committee was asked to specify a planning model, that is, to describe and provide a rationale for the approach used to establish the Nutrition Standards. The existing planning model for Nutrition Standards is based on application of the 1995 Dietary Guidelines for Americans and the 1989 RDAs for selected nutrients, as averaged over 5 school days. Many terms are associated with the Nutrition Standards. The term Nutrition Standards itself reflects the comprehensive list of the overall dietary goals of interest, regardless of whether they are currently required or only recommended by USDA. The required components of the Nutrition Standards are called key nutrients. 2 The term nutrient standards is familiar to many who work with the school meal programs and refers to those quantitative values that specify the amounts of the key nutrients for the age-grade groups 3 (on a 5-day average). The calculations on which these amounts are based are described later in this chapter. The nutrient standards are incorporated directly into the NBMP approach (Appendix H). For FBMP, however, the nutrient standards were used in developing the specifications for the meal standards 4 that reflect the food components and amounts in the Meal Requirements (Appendix G), and SFAs may use the nutrient standards as a measure when monitoring the quality of the menus they have planned. Furthermore, some have used the term indicator nutrients to refer to those key nutrients that serve as a useful proxy for major food groups and for identifying dietary patterns that are likely to include a range of essential nutrients. Vitamin C, for example, if it is present in an adequate amount in food sources, is likely to indicate the presence of important amounts of certain other vitamins and trace elements. Recently, the term nutrients of concern (or, sometimes, indicators of concern) has been used to refer to nutrients for which current levels of consumption may be problematic (e.g., calcium). Nutrients of concern are not specified within current USDA provisions for school meals, but one or more of the key nutrients may be nutrients of concern. Calculation of Amounts of Key Nutrients for Age-Grade Groups (Nutrient Standards) The Nutrition Standards specify that the lunch meal contain one-third of the 1989 RDA for key nutrients and that the breakfast meal contain one-fourth of the 1989 RDA for key nutrients. However, the Nutrition Standards must be quantified in a manner that tailors the amounts for the age-grade groups receiving the school meal—for example, children in a school for grades 7–12, all of whom receive meals from a single cafeteria line. For several nutrients, this quantification 2 Practitioners have tended to informally refer to the key nutrients as divided into two groups: So-called leader nutrients (calories, protein, calcium, vitamin A, vitamin C) and Dietary Guidelines for Americans nutrients (the percentage of calories from total fat and the percentage of calories from saturated fat). 3 As used in the school meal programs, age-grade groups actually are designated by grades, such as kindergarten through grade 3. 4 These standards are often referred to as meal patterns. 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 39 involves the use of weighted RDAs. The use of weighting allows the determination of a single representative value when children in the age-grade group have different RDAs on the basis of their age and gender. These calculated values have been called nutrient standards; but, to avoid unnecessary confusion, this report incorporates these values into the broader term Nutrition Standards. From this point forward in the report, the term Nutrition Standards is used to encompass the general list of nutrients and other dietary components, including the quantities calculated for each age-grade group. Table 2-2 shows the amounts of nutrients that are to be provided to schoolchildren on the basis of the current Nutrition Standards and as specified for relevant age-grade groups. These amounts are based on a 5-day average. Therefore, over the course of a school week, the average nutrient content per meal must be consistent with these amounts. The age-grade groups included in Table 2-2 are those specified for the various menu planning approaches that are described in the “Meal Requirements” section below. Different menu planning approaches incorporate different age-grade groups. TABLE 2-2 Current Nutrition Standards: Amounts of Nutrients That Are to Be Provided to Children, by Age-Grade Groupa,b Lunch Breakfast Food Grades Grades Grades Component Preschool K–3 K–6 4–12c 7–12 Preschool K–12 7–12 Calories 517 633 664 785 825 388 554 618 Fat (% of kcal) ≤30 ≤30 ≤30 ≤30 ≤30 ≤30 ≤30 ≤30 Saturated fat (% of kcal) <10 <10 <10 <10 <10 <10 <10 <10 Protein (g) 7 9 10 15 16 5 10 12 Calcium (mg) 267 267 286 370 400 200 257 300 Iron (mg) 3.3 3.3 3.5 4.2 4.5 2.5 3.0 3.4 Vitamin A (RAE) 150 200 224 285 300 113 197 225 Vitamin C (mg) 14 15 15 17 18 11 13 14 NOTE: g = grams; K = kindergarten; kcal = kilocalories (or calories, as used in this report to refer kilocalories); mg = milligrams; RAE = retinol activity equivalents. a These amounts are also referred to as “nutrient standards.” b The preschool group is used in all menu planning approaches, the K–3 group is used in the traditional food-based approach and is optional in the enhanced food-based and nutrient-based approaches, the K–6 group is used in the enhanced food-based and nutrient-based approaches, the grade 4–12 group is used in the traditional food-based approach, and the grade 7–12 group is used in enhanced food-based and nutrient-based approaches and is optional in the traditional food-based approach. Menu planners are encouraged to use smaller age-grade groupings to better meet the nutritional needs of students. At a minimum, they must use the established grade groups (e.g., the K–6 and 7–12 groups) or the other grade options (e.g., the preschool and K–3 groups). School food authorities (SFAs) can modify the age-grade groups to reflect the grades within that SFA. If one age-grade is outside the established range of the K–6 or the grade 7–12 group, the school may use the age-grade group in which the majority of children fit. If more than one age-grade is outside the range, an SFA must use two menus and the relevant calculated quantities as specified by the Nutrition Standards. c The SFA or school always has the option of serving the meal appropriate for the grade 4–12 age-grade group for all students in the school district or school under the traditional food-based approach for lunch. SOURCE: Derived from USDA, 2000b, 2008f. 

40 NUTRITION STANDARDS AND MEAL REQUIREMENTS Meal Requirements School menu planners have some flexibility to plan nutritious and appealing meals that vary from day to day, but these meals must provide the required components of the Nutrition Standards on a daily basis, as averaged over the school week (Table 2-2). These standards, as specified by USDA, guide the menu planning process. The term Meal Requirements refers to the set of meal standards used to develop menus and meals so as to implement the Nutrition Standards. The meal standards are specific to the type of menu planning process used (the FBMP approach or the NBMP approach) and are delineated in Appendixes G and H. Menu Planning Approaches The two menu planning approaches and related meal standards serve several important purposes. In particular, they • facilitate meal planning, • enable local SFAs to decide what specific foods they will serve, • help ensure that the Nutrition Standards will be met over the course of the 5 consecutive days of the school week, and • enable local SFAs to serve meals that qualify for reimbursement. Characteristics of the FBMP and the NBMP approaches are summarized in Table 2-3. Aspects of the Meal Requirements that are specific to each approach are indicated by gray shading. Food-based menu planning approaches There are two food-based approaches, the traditional and the enhanced approaches. The first two columns of Table 2-3 show that the traditional food-based approach is similar to the enhanced food-based approach but that the enhanced food-based approach uses a larger number of servings of vegetables and fruits and of grains and breads at lunch. It also uses different age-grade groups (see the rows Reimbursable lunch [as offered standard] and Age-grade groups: Lunch). The as served standard for a reimbursable breakfast is the same for both the traditional and the enhanced FBMP approaches. Nutrient-based menu planning approaches The two NBMP approaches (nutrient standard menu planning and assisted nutrient standard menu planning) are the same and appear together in the rightmost column of Table 2-3. Both approaches develop menus utilizing a computerized process to ensure that the nutrient content conforms to the standards. The NBMP approach is implemented by the use of USDA-approved computer software for nutrient content analysis. Either the SFA itself or (with assisted planning) an outside source uses the software to plan and analyze menus. The state agency must approve the initial cycle menus, recipes, and other pertinent information, such as food specifications. Alternative approaches A fifth option (not shown) is known as the alternative menu planning approach or as any reasonable approach, as cited in regulation (Healthy Meals for Children Act, P.L. 104-149 (May 29, 1996): § 9). It allows states and school districts to develop their own approaches, but these are subject to the requirements established in the USDA regulations. 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 41 Comparison of the Approaches For the NBMP approaches, the meal standards regarding the nature of the menu items are relatively broad (e.g., at a minimum, a lunch must contain an entrée, fluid milk, and a side dish). The actual number of menu items required each day depends on the number needed to meet the Nutrition Standards averaged over a week. In contrast, schools using the FBMP approaches must meet portion size specifications for all the food components in the lunch menu (namely, fluid milk, meat or meat alternate, vegetable or fruit, and grains or bread). The portion size specifications used in the FBMP approach differ somewhat by age-grade group, as shown in Appendix G. On the basis of data from the third School Nutrition Dietary Assessment (USDA, 2007a), approximately 48 percent of the schools that offer lunch use the traditional food-based method of menu planning, 22 percent use the enhanced food-based method, and 30 percent use a version of the nutrient-based method. Offer Versus Serve Under existing requirements, schools must offer—that is, make available on the cafeteria line—the menu items that on a daily basis comprise a reimbursable meal. The “offer versus serve” (OVS) provision, which was mandated by law for senior high school lunch programs in 1976 (USDA, 1976) and currently is a widely used option for lower grades, introduced a new standard: the as served standard for reimbursable meals. As shown in Table 2-3 under both menu planning approaches, the as offered standards are distinct from as served standards for meals. For schools that take part in OVS, a student may select—that is, be served—fewer menu items than the number that must be offered, but the selected menu items must match those required under the OVS provisions (i.e., meet the as served meal standard shown in Table 2-3 for a reimbursable meal). Although students may decline specified foods, the cost (if any) of the meal to the student stays the same. It should be noted that a meal as served does not necessarily equate to what a student may actually consume. For schools that do not take part in OVS, the as offered standard applies. Finally, in regard to Meal Requirements overall, the SMI calls for periodic (usually every 5 years) reviews of a school’s meal program. The goal is to promote adherence to the standards and to provide the technical assistance that may be needed. The SMI reviews are carried out by the state authorities, and at times they are assisted by USDA staff. Key elements of the review include analysis of a week’s set of menus for nutrient content, the school’s implementation of the age-grade group specifications, and validation that the school is serving the meal as planned (personal communication, R. Orbeta, Food and Nutrition Service, USDA, September 2008). Although Table 2-3 provides a general overview of the components of the current Meal Requirements, the committee must address the specific meal standards within the Meal Requirements. The current meal standards for the FBMP approach are presented in Appendix G, and those for the NBMP approach appear in Appendix H. 

42 TABLE 2-3 Characteristics of Menu Planning Approaches for School Mealsa Food-Based Menu Planning Approachb Nutrient-Based Menu Planning (Nutrient Standard Menu Planning or Assisted Nutrient Standard Menu Planning) Characteristic Traditional Approach Enhanced Approach Approachc How meals are Food components and food items/Nutrient Same as traditional Nutrient content analysis; must contain minimum planned and content analysis approach required menu items evaluated Food components, Minimum quantities as established for food Same as traditional Menu items as established by the menu planner to food items, and menu components and food items (see Appendix G) approach meet the Nutrition Standards calculated for age- items offered grade groups (see Appendix H) Computer hardware • Not required Same as traditional • Menu planning is based on nutrient content and software • State agency will conduct nutrient analysis approach analysis on SMI review • The SFA or school must have hardware and USDA-approved software and use nutrient content analysis to plan meals to meet the Nutrition Standards calculated for the age-grade group or use an outside source for assistance with analysis of the appropriate Nutrition Standards before reimbursable meals are served Reimbursable lunch A minimum of five food items in specific Increased quantities The number of menu items for the day must be (as offered standard)d quantities must be offered from the following of V/F and G/B; offered in the planned quantities to meet the week’s four components: otherwise, it is the specified levels (with a minimum of three menu • one serving of fluid milk same as the items): • one serving of M/MA traditional approach • fluid milk • two servings of V/F • entrée • one serving of G/B • side dish Reimbursable lunch • OVS is required in senior high schoolse; Same as the OVS is required in senior high schoolse; if three (as served standard) students must select three of the five items traditional approach items are offered, students may decline one; if four • OVS is optional in grades below the senior or more items are offered, students may decline two high school level; schools may choose to • Students must always take the entrée have students select either three or four of • OVS is optional in grades below senior high the five items school level • The number of menu items that students can decline is the same as stated above 

Age-grade groups: Lunch Established age-grade groups: Established age- Options: • preschool grade groups: • established grade groups: preschool, K–6 and 7– • K–3 preschool 12 (K–3 optional) f • grades 4–12 • K–6 • established age groups: ages 3–6, 7–10, 11–13, • grades 7–12 (optional) f • grades 7–12 and 14–17; or • K–3 (optional) f • customized age groups Reimbursable A minimum of four required foods must be Same as traditional The number of menu items for the day must be breakfast (as offered offered in specific quantities: approach offered in the planned quantities to meet the week’s standard)d • one serving of fluid milk, specified level (with a minimum of three menu • one V/F, and items) • two M/MA or two G/B or one of each Reimbursable • Students must select at least three food Same as traditional • Students may decline a maximum of one menu breakfast (as served items from the four items offered. approach item, regardless of the number of items offered standard) (OVS breakfastg) Age-grade groups: Established ages or grades: Established ages or Options: Breakfast • preschool grades: • established grade groups: preschool and K–12 • K–12 • preschool (7–12 optional) • K–12 • established age groups: ages 3–6, 7–10, 11–13, • grades 7–12 and 14 and older; or (optional) • customized age groups NOTE: This table does not include information on the alternate menu planning approach (any reasonable approach). The state agency must approve any approach that differs in a major way from those listed in this table. G/B = grains and breads; K = kindergarten; M/MA = meat/meat alternate; OVS = offered versus served V/F = vegetables/fruits. a Key elements of the Meal Requirements are designated by gray shading. b See Appendix G for descriptions of the meal standards for the food components and food items. c See Appendix H for descriptions of the meal standards for the nutrient-based menu planning approach. d This is the standard that schools must meet when they are not operating under the OVS provisions. e As defined by the state educational agency. f Optional age-grade groups can be used if other established ages or groups do not accurately reflect the grades within that SFA. g Offer versus serve is optional for all grades. SOURCE: Adapted from USDA, 2007b. NOTE: Excessive energy intakes for some age-gender groups may not have been identified because of underreporting. 43 . 

44 NUTRITION STANDARDS AND MEAL REQUIREMENTS Cost Reimbursement for Meals Federal reimbursement of meal costs is the major source of cost reimbursement for meals and is conducted on the basis of prescribed record-keeping requirements, which are the responsibility of the SFA. Trained cashiers check the meals selected by the child against meal standards described in the previous section. Then, consistent with the level of reimbursement for that child, they tally the number of qualifying full-price, reduced-price, and free meals. This activity is shown at the end of the schematic in Figure 1-1 in Chapter 1. Meal reimbursement is intended for meals that have been prepared, offered, and selected consistent with the Nutrition Standards and Meal Requirements. The three main budgetary inputs for providing high-quality, nutritious school meals that apply to both the NSLP and the SBP school meal programs are (1) federal per meal cash reimbursements, (2) the costs paid by participating children, and (3) the costs for USDA commodities. Two smaller federal programs also provide input. Each of these inputs is described briefly below. Federal Cash Reimbursements USDA provides per meal cash reimbursements to participating public and nonprofit private schools and residential child care institutions for meals that meet the federal Nutrition Standards. USDA provides the reimbursement to state agencies, which, in turn, disburse the monies to the SFAs within their states. In fiscal year (FY) 2007, cash payments were nearly $10 billion (USDA, 2008g). The reimbursement rates for the 2008–2009 school year appear in Table 2-4. The reimbursement rate is adjusted annually on the basis of an index linked to the Consumer Price Index (which reflects changes in prices compared with those in the previous school year) and is published in the Federal Register by July 1 of each year to aid schools in planning for the new school year (Amendments to the National School Lunch Act and the Child Nutrition Act, P.L. 92- 433, 1972). 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 45 TABLE 2-4 Federal per Meal Reimbursement Rates for School Meals in the Contiguous States, July 2008 Through June 2009 Program, Cost Basisa Reimbursement Rates School Cost of meal to breakfast Non-Severe Need Severe Needb child Free $1.40 $1.68 $0 Reduced $1.10 $1.38 ≤$0.30 price Paid $0.25 $0.25 Variesd School lunch <60% Were Free or Reduced ≥60% Were Free or Reduced Pricec Pricec Free $2.57 $2.59 $0 Reduced $2.17 $2.19 ≤$0.40 price Paid $0.24 $0.26 Variesd a Eligibility criteria are discussed in Chapter 1. b Severe need refers to schools at which at least 60 percent of the lunches served during the second preceding school year were free or were provided at a reduced price (or, for new programs, if this requirement would have been met). c Determined during the second preceding school year. d Varies by school district or SFA. SOURCE: USDA, 2008h. Special provisions available through USDA (referred to as Provisions 1, 2, and 3) are aimed at reducing the application burden. The three provisions allow for providing meals at no cost to students, given that the schools follow certain application and claiming procedures (as outlined in regulation) (USDA, 2001c). Provision 1 is available to schools in which 80 percent of enrolled children are eligible for free or reduced-price meals. Students who qualify for free meals can be certified as eligible to receive them for a 2-year period. Provision 2 requires schools to provide free meals to all participating children and may certify children as eligible to receive free and reduced-price meals for up to a 4-year period. Provision 3 also requires schools to provide free meals to all participating children but changes the process by which federal cash and commodity assistance received by the school is determined (USDA, 2002c). The reimbursement rate for the free meals is the same as that indicated in Table 2-4. Cost Paid by Participating Children Meals are provided to children at either full price (called “paid” meals in Table 2-4), reduced-price, or free. By regulation, the cost of a meal to a child receiving a free or reduced- price meal may not be increased above the amount published in the Federal Register (currently the amount in the rightmost column of Table 2-4), but the cost for children paying full price may be set by the school district or SFA. Experience has shown that increasing the cost for full-price meals decreases the rate of participation by children living in households whose income exceeds the maximum allowed for reduced-price meals. In some cases, a decreased rate of participation may lead to higher per meal costs to the SFA because non-food costs do not decrease to the same degree. These limitations mean that the school food service planners must be very resourceful in controlling food, labor, and other costs, despite rising prices. 

46 NUTRITION STANDARDS AND MEAL REQUIREMENTS USDA Commodities USDA agricultural commodities (called commodities here for convenience) are unprocessed or partially processed foods. USDA’s Commodity Distribution Program began in response to the Depression in the 1930s. It assisted farmers by purchasing their surplus products, and it provided food for school lunches for millions of schoolchildren who were unable to pay for lunch (USDA, 2007c). The Commodity Distribution Program provides commodities to schools that participate in the NSLP. The overall value of the commodities provided was about $1 billion in FY 2007 (USDA, 2008g). The value of the commodities supplements the per meal cash reimbursements that schools receive. Local school districts are entitled to a specific dollar value of entitlement commodities each school year on the basis of the product of the total number of school lunches that they serve and a reimbursement rate. In addition, if USDA has a surplus of particular commodities, states may order whatever amount of these bonus commodities they can use. These do not count against a state’s regular entitlement commodities. Market conditions and agricultural surpluses determine the availability of bonus commodities. In recent years, bonus commodities have become less common because of improved market conditions for agricultural producers, more precise crop planning, and tighter supply-chain management (CFPA, 2008). State agencies may choose from a list of more than 180 different types of products, although they may decline offerings from the list if they choose not to include them in choices made available to the school districts. On the other hand, many states allow local school districts to choose from all available USDA commodity offerings. Foods that are available for the 2009 school year include fruits and vegetables, meats, dry and canned beans, fruit juices, vegetable shortening and vegetable oils, peanut products, rice, cheese, pasta products, and flour and other grain products (USDA, 2008i). Under the Processing Program that started in 1958, commercial food processors may contract with state agencies or school districts to convert raw bulk USDA commodities into products that are more convenient and ready to use (USDA, 2008j). Much effort has been made to improve the available commodity offerings. Those offerings now include a larger proportion of fruits, vegetables, and whole grains, as well as products with reduced amounts of total fat, saturated fat, sugar, and sodium. Trans fats have been eliminated from frozen potato products and USDA is working to remove them from its other offerings (USDA, 2007d). Nonetheless, it can be a challenge for SFAs to fit the commodities into menus and recipes. Several federal agencies, the state distributing agency, and the school district are involved in decision making relating to the use of commodities on the basis of the choices of those districts. Other Federal Programs That Provide Foods to Schools Additionally, the U.S. Department of Defense Fresh Fruit and Vegetable Program operates a nationwide system that purchases and, in the 2006–2007 school year, distributed a wide variety of high-quality fresh produce to schools in 43 states, the District of Columbia, Puerto Rico, the Virgin Islands, and Guam (USDA, 2008k). The 2008 Farm Bill amended the National School Lunch Act to include the USDA Fresh Fruit and Vegetable Program. Beginning in the 2008– 2009 school year, elementary schools could apply for funding to provide fresh fruits and vegetables to all students throughout the day if more than 50 percent of their student enrollment in the NSLP was comprised of students eligible for free and reduced-price meals (Food, Conservation, and Energy Act of 2008, P.L. 110-246 (June 18, 2008): § 4304). 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 47 TOPICS RELEVANT TO REVISING THE NUTRITION STANDARDS AND MEAL REQUIREMENTS This section highlights a variety of topics that are relevant to the committee’s task of recommending revisions to the Nutrition Standards and Meal Requirements. These include applying the Dietary Guidelines for Americans and the Dietary Reference Intakes (DRIs), addressing the need for simple approaches to making revisions, helping provide a safety net to children who are at risk of insufficient intake without contributing to excessive weight gain, planning meals that students will eat, addressing cost considerations, and addressing other factors that affect the feasibility of implementing the recommendations. Appendix E lists the critical issues included within the charge to the committee, most of which are mentioned in the discussions below. Applying Dietary Guidelines to the School Meal Programs Fruit, Vegetables, Whole Grains, and Low-Fat or Fat-Free Milk Products The Child Nutrition and WIC Reauthorization Act of 2004 amended the National School Lunch Act to require the provision of increased amounts of foods that are recommended in the most recent Dietary Guidelines for Americans. These include fruits, vegetables, whole grains, and low-fat or fat-free milk products. The increased consumption of such food groups would likely call for the decreased consumption of other food groups (for example, meats and refined grains) and food components (such as hard fats or added sugars) or both to avoid excessive energy intake. Addressing these issues requires the consideration of the FBMP and NBMP approaches. These two approaches and their meal standards currently differ with regard to the minimum number of servings and the minimum serving sizes of fruits and vegetables and fluid milk, and neither requires (but both encourage) the provision of whole grains. As shown in Table 2-3, the FBMP approaches are much more specific. The regulations specify that all schools must provide fluid milk in a variety of fat contents, but they do not restrict the types of fluid milk that are offered (Child Nutrition and WIC Reauthorization Act, P.L. 108-265 (June 30, 2004): § 102). The recommended daily intake of milk specified by the Dietary Guidelines for Americans is less for young children than for older children (see Appendix C), but offering smaller serving sizes to the younger children might lead to operational problems for SFAs that are working to provide meals to children who span a considerable age range. The definition of whole grain will need to be considered. The method of assessing intake (see Chapter 4) distinguishes between 100 percent whole grain and various mixtures of grains. In the marketplace, most foods that contain whole grain have mixtures of grains. The term whole grain is not defined by Food and Drug Administration regulations, and the agency has not provided a definition of a whole-grain product or a whole-grain serving. To assess how well a school is meeting the Nutrition Standards should they include whole grains in menus, the definition of whole grain will need to be clear. Sodium, Cholesterol, Fiber, and Trans Fat The Dietary Guidelines for Americans include quantitative recommendations for limiting sodium and cholesterol intake and for increasing fiber intake. The guidelines also recommend limiting the intake of trans fat but do not specify an intake level. Especially with regard to 

48 NUTRITION STANDARDS AND MEAL REQUIREMENTS limiting sodium intake, it may be challenging to obtain easily prepared foods that children will find appetizing. Planning for Subsequent Revisions to Dietary Guidelines for Americans By law, the need for revisions to the Dietary Guidelines for Americans must be addressed every 5 years. To date, the Dietary Guidelines Advisory Committees have recommended changes every 5 years. Especially since the next revision to Dietary Guidelines for Americans is expected in 2010, it may be helpful if the revisions for the Nutrition Standards and Meal Requirements for school meal programs can include a way to accommodate future changes to the Dietary Guidelines for Americans. Applying Dietary Reference Intakes to the School Meal Programs Relatively new nutrient reference values known as the DRIs (IOM, 1997, 1998, 2000a, 2001, 2002/2005, 2005) are now widely accepted and have even been incorporated into the Dietary Guidelines for Americans. The committee will examine ways to apply the DRIs to the development of revised Nutrition Standards for the school meal programs (The current Nutrition Standards are based on the 1989 RDAs.) Incorporating the Dietary Reference Intake Planning Approaches for School Meals A major element of the Institute of Medicine (IOM) report Dietary Reference Intakes: Applications in Dietary Planning (IOM, 2003) is the conclusion that the RDA is not an appropriate planning goal. Instead, the Estimated Average Requirement is the appropriate reference value to use to set a low prevalence of inadequacy as the planning goal. The IOM report provides some guidance on the planning of menus to achieve specified nutrient intakes and briefly addresses two options for the application of a framework for the planning of school meals for different age groups. The report also presents a nutrient density approach that may be applied to heterogeneous groups (groups that encompass individuals of both genders and individuals with different nutrient and energy requirements, which is the case in schools). The report notes, however, that the planning task is complex and involves considerations related to program goals, nutritional aspects (such as the selection of target nutrient intake levels), and program implementation. It does not provide specific guidance on how to address the complexity of the task. The development of revisions to the Nutrition Standards and Meal Requirements for school meal programs must take the IOM planning report’s guidance and related considerations into account. Specifying Age-Grade Groups Nutrient and energy needs differ by age and, in some cases, by gender. Currently, the regulations for school meal programs specify a number of age-grade groups (see Appendix G, for example) and make no distinction by gender. DRI age groups differ somewhat from the ages covered by the USDA-specified age-grade groups. The DRIs are set for children ages 4 through 8 years, 9 through 13 years, and 14 through 18 years; and they give separate values for males and females beginning at age 9 years. Because of the discrepancies between the age-grade groups of the school meal programs and the age categories for DRIs, a range of nutrient values for a specific nutrient may apply to each age-grade group (see Chapter 5). During Phase II of this study, the committee will specify age- 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 49 grade groups and propose the amounts of the required components of the Nutrition Standards by age-grade group (as was done in Table 2-2 for the current standards). These amounts would be used for nutrient-based menu planning and the evaluation of menus planned by use of the FBMP approach. Recommending Energy Levels Energy needs differ by age, as mentioned above, but also by physical activity level and body size (which vary greatly, especially in grades 7 through 12). Recommendations for energy will need to consider the great diversity of needs of the children being served. In the revision of Nutrition Standards and Meal Requirements, it may be appropriate to recommend both minimum and maximum energy levels. Specifying Nutrients to Be Covered by the Nutrition Standards Currently, regulations specify quantitative requirements for energy, protein, calcium, iron, vitamin A, vitamin C, total fat, and saturated fat (Table 2-1). In addition, the Nutrition Standards encourage program operators to reduce sodium and cholesterol levels and to increase fiber levels in the food items in their menus (the regulations provide no further specification). The DRIs include reference values for all of these nutrients plus many more, and the 2005 Dietary Guidelines for Americans (HHS/USDA, 2005) identified several nutrients of concern for children. These developments indicate the need for the reassessment of the nutrients covered in the Nutrition Standards. Addressing the Need for Simple Approaches Because revisions to the Nutrition Standards and Meal Requirements will need to be implemented in a wide variety of settings, one challenge is to develop standards whose implementation is simple enough for all food service operations, including those that face challenging operational problems or financial limitations. School meals food service operations may differ in a variety of ways. These include but are not limited to the following: • school size, • number of schools served, • number of children served, • the grades of the children served, • the distance of the feeding site from the kitchen, • funding, • the qualifications and training of the food service personnel, • the computer expertise of the SFA, • the number of personnel relative to the task, • the menu planning approach used, • the time available to serve meals, • equipment and storage facilities, and • the cultural and socioeconomic diversity of the student body. 

50 NUTRITION STANDARDS AND MEAL REQUIREMENTS Evidence suggests that the implementation of the approaches and standards put forth by the SMI has required careful planning, resources, and time. To facilitate the implementation of the Nutrition Standards and the serving of appropriate meals, USDA has made many resources available to school food service operators. For example, USDA provides a computer disk called SMI Tools for Success for School Food Authorities that contains a 71-page document called SMI Frequently Asked Questions, a 125-page document called The Road to SMI Success, and a 127- page document called Nutrient Analysis Protocols: How to Analyze Menus for USDA’s School Meals Programs. USDA offers grants for training program operators on SMI guidelines to state agencies as well. Nonetheless, the implementation of SMI has been challenging for many SFAs, as indicated in Chapter 1. Providing a Safety Net for Vulnerable Children Without Contributing to Excessive Weight Gain From their inception, the school meal programs have played a key role in providing a safety net for low-income U.S. children to help ensure that they are well fed. As obesity has become a common occurrence among the nation’s children, however, many people are concerned that revisions to Nutrition Standards and Meal Requirements for school meals consider both the potential contributions of school meals to childhood obesity and to fostering the food security of children, where food security 5 means “access at all times to enough food for an active, healthy life” (IOM, 2006a). Low Food Security Low food security is described as “reports of reduced quality, variety, or desirability of the diet” and “little or no indication of reduced food intake” (USDA/ERS, 2007a, table) in the household. Very low food security is described as “reports of multiple indications of disrupted eating patterns and reduced food intake” in the household (USDA/ERS, 2007a, table). The prevalence of low food security varies inversely with changing economic conditions; the prevalence increases when economic conditions worsen. Between 1995 and 2005, 14.8 to 17.6 percent of U.S. households with children under the age of 18 years were assessed to be food insecure. For logistical reasons, these data exclude approximately 800,000 to 1.2 million homeless children (NCH, 2008), who are likely to be at high risk of disrupted eating patterns and reduced food intake. Overall, 0.8 percent of children lived in a household with very low food security, in which limited food availability was reported to have led to restricted intake for one or more children in the household (USDA/ERS, 2006). Relationships of Low Food Security with Body Weight Status In the United States, low food security does not appear to be associated with underweight in schoolchildren (Bhattacharya et al., 2004). In fact, less than 3 percent of children ages 5 through 18 years were classified as underweight in an analysis of the data from the 1999–2004 National Health and Nutrition Examination Survey (USDA, 2008l). Importantly, it appears that children in households with low food security are as likely or more likely to be obese or overweight than children in food-secure households (Alaimo et al., 2001; Bhattacharya et al., 2004; Casey et al., 2006; Martin and Ferris, 2007; Gunderson et al., 2008). In a recent study of children ages 10 5 Hunger and food security are global issues, and related definitions used in other countries vary. 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 51 through 15 years, Gunderson et al. (2008) reported that 25 percent of the children in households with low food security had body mass indexes that were greater than the 95th percentile of Centers for Disease Control and Prevention growth charts (obese). About one-third of all schoolchildren are overweight or obese (Table 1-2 in Chapter 1). The revision of the Nutrition Standards and Meal Requirements will need to help ensure that school meals contribute to both food security and healthy weight. Planning Meals That Students Will Eat Revisions to the Nutrition Standards and Meal Requirements will be valuable only to the extent that students consume the food that is served. Reportedly, a major hurdle to the potential revisions is a lack of student acceptance of the changes brought about by the revisions (SNA/SNF, 2007). One study reported that the significant factors affecting students’ decisions to participate in the NSLP were the quality and the variety of foods offered (Marples and Spillman, 1995). Wojcicki and Heyman (2006) found that the availability of healthy food options on the menu was followed by higher rates of student participation in the NSLP. Other factors, however, may have been related to the increase in participation, such as increased eligibility for free and reduced-price meals. Some schools provide self-service salad bars to encourage the consumption of greater amounts of fruits and vegetables. Nevertheless, Adams et al. (2005) found no association between the availability of salad bars and fruit and vegetable consumption, but they did find that the consumption of fruits and vegetables was positively related to the number of those items offered at the salad bars. Certain types of menu changes offered to improve the rates of adherence to the Dietary Guidelines for Americans could have an adverse effect on student acceptability of school meals and, therefore, on the rate of program participation, especially if the changes are made in an abrupt manner. On the other hand, Wechslar and colleagues (1998) reported that the implementation of strategies to promote the acceptance of low-fat milk in elementary schools in an inner-city neighborhood doubled its selection (to 57 percent of the milk selected). Such factors will need to be considered during the process of updating the standards. Based on information available, meal acceptance is a factor to be taken into account in making recommendations to update the Nutrition Standards and Meal Requirements. However, as a general matter, student acceptance of foods is a complex topic for which there are relatively little data and many unknowns. To appropriately address the issue in a way that provides pragmatic guidance for practitioners requires considerations outside the scope of this study. Relevant topics may range from the discovery that children drink milk more readily if it is packaged in a carton showing a favorite cartoon character, to experimenting with recipes that are low in sodium but use spices acceptable to children to “up” the flavor. Such information is important for implementation of new meal standards, but much of the research is only now emerging. Addressing Cost Considerations Many factors affect the cost of school meal programs. Among these factors are the costs of food, labor, utilities, and fuel (for off-site delivery); indirect costs; equipment depreciation; and the availability of federal commodities to the program. Some of these factors are influenced by the number of children served, by changes in the operation of public schools (e.g., subdividing large high schools into smaller free-standing units), the number of children with special health 

52 NUTRITION STANDARDS AND MEAL REQUIREMENTS care needs that include dietary modifications, state and local purchasing options, and the cultural diversity of the school population. In difficult economic times, an increasing number of school food service operations are required to cover all their costs without receiving financial support from the school district. In many parts of the country, there is debate about whether school meal programs should be self- supporting or whether they should be subsidized to some degree because the provision of nutritious meals is part of the mission of the school. Importantly for this study, it has been found that the improved implementation of current Nutrition Standards typically results in increased costs at the local level. In a survey conducted to examine the implementation of school wellness policies, 78 percent of school districts reported increased costs, mainly as a result of the increased cost of food (SNA/SNF, 2007). Further improvements in menus may contribute to further cost increases. Therefore, revisions to the Nutrition Standards and Meal Requirements will need to consider costs. As USDA does not anticipate that additional funding will be available to schools so that they may implement any new revisions of the Nutrition Standards and Meal Requirements resulting from the committee’s recommendations, the request to the committee is that recommendations be designed to be economical. Other Factors Affecting Feasibility The feasibility of implementing recommendations for revisions to the Nutrition Standards and related Meal Requirements may be affected by the factors mentioned above that relate to the complexity or the simplicity of the recommendations, the diversity of food service operations and facilities, personnel, cost, student acceptability, and student participation. Among the other factors that may affect the feasibility of implementing the revisions are the following: • Variability in the methods that states and districts use to operate the school meal programs. Federal regulations set minimum requirements for Nutrition Standards and Meal Requirements for the operation of school meal programs; but states may add requirements, and many do so. • Determining the contribution of mixed foods to meeting the meal standards. The food group contributions of the components of purchased products such as pizza, beef patties (which differ in their fat contents), and certain juice products (which differ in the percentage of juice) can be difficult to determine. The USDA’s Food and Nutrition Service works directly with commercial food-processing firms and operates a voluntary federal labeling program called the Child Nutrition (CN) Labeling Program. Figure 2-2 shows an example of a CN label. Costs are associated with obtaining the approved CN label. 

DESCRIPTION AND TOPICS RELEVANT TO THEIR REVISION 53 FIGURE 2-2 Example of a CN label. A CN label specifies the number of portions of one or more food groups that one serving of the food provides. SOURCE: USDA, 2008m. • Available nutrient information. By law (Nutrition Labeling and Education Act of 1990, P.L. 101-535), the current Nutrition Facts panel on food labels includes information on the product’s content of the 11 nutrients listed in Table 2-1. The law does not require the listing of any other nutrients. Some of the nutrients that were identified in the Dietary Guidelines for Americans as nutrients of concern for children (such as potassium, magnesium, and vitamin E) are listed on few food labels (manufacturers may list these and other nutrients at their discretion). Products that bear the CN label are not required to have a Nutrition Facts panel; however some manufacturers add the panel to CN-labeled products voluntarily. Since SMI reviews require that nutrition information for all commercially prepared food products is kept on file, SFAs can contact the manufacturer directly to obtain that information. Because many school meal program operators rely on information obtained from food labels and product specifications to plan and assess menus, the availability of nutrient information merits consideration. • Expression of the vitamin A standard. If proposed revisions include a standard for vitamin A intake, consideration will need to be given to the difference in units used in the DRIs (Retinol Activity Equivalents) and on the Nutrition Facts panel and product specifications (international units). The availability of a method for conversion from one to the other set of units would be useful. Currently, only schools using the NBMP and USDA-approved software are able to calculate and report the nutrient analysis in both units (USDA, 2006a). • Flexibility of the SBP and menu structures. Current regulations provide schools with the flexibility to provide a typical breakfast that minimizes the burden on school food service operations and encourages broad participation in the SBP. Consideration may need to be given to maintaining such flexibility while improving compliance with the Dietary Guidelines for Americans. • Portion sizes. Offering different portion sizes (especially of prepackaged foods, such as fluid milk) to accommodate the different nutritional needs of children in different grades may be operationally difficult to implement at the local school level. Attention to procurement logistics and economies of scale that may pose limitations to this approach is warranted. • The school nutrition and health environment. The increased consumption of foods from the school meal programs rather than of competitive foods has been shown to improve dietary intake (Cullen et al., 2008). Nevertheless, in many schools, reimbursable meals have competition from foods that are available à la carte and at snack bars, school stores, canteens, and vending 

54 NUTRITION STANDARDS AND MEAL REQUIREMENTS machines. In many cases, these options have been introduced with the intent of generating income to benefit the school or to help the school food operation break even. Indeed, according to the School Health Profiles survey (CDC, 2008b), a large majority of secondary schools in 27 states and 11 large urban school districts allowed students to buy competitive foods onsite. Thus, for schools that retain these options, reimbursable meals planned to meet revised Nutrition Standards and Meal Requirements need to be sufficiently attractive to students so that students chose the school meals rather than the other options. Factors found to affect students’ decision to participate in the school lunch program include the length of the lunch period and the amount of time that one must stand in line to obtain the food (Marples and Spillman, 1995). Thus, meal patterns that lend themselves to quick service may be beneficial. The report Nutrition Standards for Foods in Schools (IOM, 2007) addresses in detail the school environment and the foods and beverages sold outside the school meal programs. • The market environment. Some of the challenges in revising the Nutrition Standards and Meal Requirements for school meals extend beyond the efforts of program operators and administrators. For example, many of the processed foods that are used in school meal programs to save time and reduce labor costs are high in sodium. If revised standards call for foods that differ from those offered in the general market, the food industry would require time to respond with palatable products. SUMMARY As described in this chapter, the revision of the Nutrition Standards and Meal Requirements for the school meal programs necessitates attention to a large number of topics. These topics range from updates in dietary and nutrient recommendations to the feasibility of implementing the changes and the costs involved. The next chapter describes the committee’s working principles, criteria, and overall approach to developing recommendations for revisions to the NSLP and the SBP.