PHA Supports USDA’s Proposed Changes to Child Nutrition Program Meal Patterns

The U.S. Department of Agriculture (USDA) is revising the meal patterns for its child nutrition programs – which include the National School Lunch Program, School Breakfast Program, Summer Food Service Program, and Child and Adult Care Food Program (CACFP) – to be consistent with the Dietary Guidelines for Americans, 2020-2025. These changes are intended to bring the programs in line with the latest nutrition science, while also ensuring schools and early childhood education settings can plan appealing meals that encourage intake of key nutrients essential for children’s growth and development.

As a National Ally of the National CACFP Sponsors Association, Partnership for a Healthier America (PHA) supports USDA’s efforts to further align the CACFP meal patterns with the Dietary Guidelines in a way that prioritizes food equity and encourages consumption of foods that support young children’s health.

Some of USDA’s proposed changes that would affect CACFP include establishing:

• First-ever added sugar limits
• New stricter sodium limits
• New flavored milk restrictions
• More flexibility to substitute vegetables for grains in programs that primarily serve American Indian or Alaska Native children
• Permission for nuts and seeds to credit for the full meat/meat alternate component
• Various terminology changes and a regulatory definition of whole grain-rich

PHA supports these proposed changes, as they have a strong potential to improve the food landscape for our nation’s youngest eaters. However, we encourage USDA to ensure its revised nutrition standards are equitable and achievable for all schools and early childhood education settings to implement, as participation in these programs is a vital safety net for children’s health and school readiness.

We commend USDA’s focus on food equity by proposing updated nutrition standards to help reduce diet-related disease, while also offering greater flexibility for traditional foods as well as locally grown, raised or caught food items. In particular, PHA supports allowing institutions and facilities, or sponsors, as applicable, that serve primarily American Indian or Alaska Native children to substitute vegetables for grains and breads to meet cultural preferences. We suggest that USDA broaden the standard to provide permission to more institutions, facilities, or sponsors who wish to substitute vegetables for grains or breads to do so for cultural reasons. For example, PHA suggests USDA provide this permission to schools and care settings where American Indian, Alaska Native, and Hawaiian Native students represent a notable portion (e.g., 25% or more) of the student population, but do not make up a majority of the student population.

USDA’s approach also reflects an important recognition that the food industry must be engaged in and support program operators by developing, marketing, and supplying products that support children’s health. Since its inception, PHA has leveraged the power of the food industry to bring lasting solutions that are good for health and good for business. Food manufacturers, like Happy Family Organics, have led the way by adopting voluntary business practices for increasing servings of vegetables, reducing sodium and added sugars, and including more whole grain-rich ingredients in their products.2 PHA would like to see these efforts continued and recognizes that successful product innovation and reformulation takes multiple years to implement.

PHA is committed to transforming the food landscape in pursuit of food equity – the concept that everyone, no matter their zip code, should have access to long-lasting affordable, good food. Alongside the White House Conference on Hunger, Nutrition and Health, PHA made a commitment to add 100 million servings of vegetables, fruits, and beans to the marketplace by 2025, and we are working toward that goal through our programs and partnerships, including Veggies Early & Often.

We can’t build food equity alone and, as a National Ally of the National CACFP Sponsors Association, we recognize the importance of CACFP in providing daily nutritious meals and snacks to more than 4.2 million children and 138,000 adults nationwide.

Proposed changes would not happen immediately. The commenting period for USDA’s proposed rule is open until May 10, 2023. After the commenting period, USDA will review all comments before making a final ruling. USDA expects to issue a final rule in time for schools to plan for the 2024-2025 school year. Not all the standards outlined in the proposed rule would be fully implemented for the 2024-2025 school year.