To assess the progress of PHA partner commitments, we work with a team of external verifiers, including:
- Food, Nutrition & Policy Consultants, LLC
- Hudson Institute
- RTI International
- Rudd Center for Food Policy and Obesity
Healthier Campus Initiative
Each post-secondary education institution participating in the Healthy Campus Initiative selected twenty-three elements across the following categories: food and nutrition, physical activity and movement, and wellness programming.
For food and nutrition guidelines, independent verifiers reviewed two days, that were selected by the independent verifier, of breakfast, lunch, and dinner menus for each campus dining venue. Menus, which included nutrient information, allowed verifiers to ensure nutrient targets were met for calories, percent calories from saturated fat, grams of trans fat, and milligrams of sodium in wellness meals. Verifiers utilized production records, planograms, recipes, nutrition facts panels, product specifications, and additional photographs to determine whether campuses offered fruits, vegetables, whole grains, and plant-based food options and limited fried foods and desserts. Procurement records, sales records, and nutrition information were also reviewed and evaluated to verify healthy vending and beverage purchases. Campuses provided additional photographic evidence to verify their use of healthy icons and calorie labeling at the point of purchase. Policies were reviewed to determine the use of local procurement programs, tray-less dining initiatives, and merchandising programs to promote nutritious options. To verify availability of water in each dining, recreation, and educational facility, campuses provided an inventory of water fountains, bottle filling stations, and access points for filtered water in at least five percent of the campus buildings, selected by the verifier.
Physical activity elements were verified through campus maps, photographs, and policies outlining walking and biking infrastructure, access to public transportation, and recreation, physical activity, and competitive sports opportunities.
Wellness elements were verified by examining policy and program documentation to determine whether integrated, comprehensive wellness programming including breastfeeding support, strategies to reduce food insecurity, health insurance benefits, and access to hands-on nutrition education and cooking classes were provided.
Healthy Hunger Relief
To verify future progress on Des Moines Area Religious Council, Capital Area Food Bank, San Antonio Food Banks and Atlanta Community Food Bank, verifiers reviewed baseline information on produce distributions, school food pantries, family markets, summer food sites and meals served, afterschool meals and weekend meals served. Verifiers also examined Capital Area Food Bank’s wellness metrics, Partners for Wellness criteria and partner list and wellness food distributions.
To verify progress for the Food Bank of Alaska, Arkansas Food Bank, Central Texas Food Bank, Connecticut Food Bank, Foodlink, Foodshare, Greater Pittsburgh Community Food Bank, The Jacobs & Cushman San Diego Food Bank, Second Harvest of San Mateo & Santa Clara Counties and Three Square Food Bank verifiers reviewed five to twelve months of inventory data along with the ranking system utilized by each food bank. The verifier cleaned the data set and provided each food bank with a report that included the percent of its total inventory that had been ranks as well as the percent of ranked inventory that fell into each category of the ranking system.
Increasing Physical Activity
Progress on commitments for the Boys and Girls Clubs of America (BGCA) was measured via the Healthy Eating and Physical Activity (HEPA) inventory and document review. BGCA clubs with early childhood or afterschool programs that had committed to implementing the HEPA standards in their programs participated in the inventory. Respondents reported whether they were “Fully Demonstrating,” “Not Fully Demonstrating” or it was “Not Feasible” to demonstrate each HEPA standard individually at their program site. In 2017, 30 clubs were selected and 28 provided data. In 2019, 40 clubs were selected for audit of which only 22 provided data. Because of the low 2019 response rate, even after multiple requests, RTI selected 10 more clubs and of these, 1 provided data. The final samples for document audit were thus 28 in 2017 and 23 in 2019. These randomly selected clubs were asked to submit program documents, including daily schedules, menus, program handbooks, and parent outreach materials, which were then reviewed by verifiers against definitions of meeting each of the HEPA standards. Verifiers analyzed the inventory to determine the percentage of clubs meeting each of the standards and the document review data to provide a confidence level on whether clubs had the documentation showing that they were meeting the standards. The confidence level is based on the document audit of clubs and reflects the proportion of audited clubs that submitted clear or plausible evidence to support a claim that they were fully implementing a commitment element. We established four categories: Highly confident=76 to 100% of clubs that said they were demonstrating a commitment element submitted clear or plausible evidence to support their claim; Confident= 51 to 75%; somewhat confident= 26 to 50%; not confident= 0 to 25%. To assist clubs in implementation, BGCA with the Alliance developed training courses and technical assistance resources to facilitate standards implementation.
To assess Mercedes-Benz, USA’s progress towards meeting its commitment, verifiers reviewed data on distribution of funds to various organizations, key activities for funds, and number of youth reached. Information on coaches was assessed via review of coach training log information including the number of coaches trained and city of placement. Engagement of Mercedes-Benz USA employees was assessed via review of a report providing dates, locations, and number of employees or dealers for engagement events. Data were summed to calculate number of opportunities and participants.
Provision of MINDBODY technology, including the platform, app, and heart rate tracking software, to Healthier Campus Initiative colleges was assessed via review of contract terms between MINDBODY and colleges. Promotional materials were reviewed by the verifier to assess marketing of classes and the PHA commitment to Healthier Campus Initiative colleges. A copy of the Ignite Wellness Challenge Toolkit was provided to assess content.
The launch and update of NET Generation by United States Tennis Association (USTA) was assessed via NET Generation website, app, and copies of NET Generation curriculum and promotional materials. The number of youth enrolled in USTA’s NET Generation was calculated from a data extract of National Junior Tennis & Learning programs, which provided youth enrollment by program. Safe play provisions were verified using public information available on NET Generation’s website outlining Safe Play program guidelines.
Progress on YMCA of the USA’s commitment to provide sub-grants to YMCA’s to offer free swimming lessons to youth was assessed using a data extract of all sub-grantees, including name, association number, and date of award. The number of new YMCAs delivering water safety programs was calculated by comparing data on YMCA’s offering water safety programs in 2018 and 2019. Data on the Diverse Abilities in Aquatics pilot was obtained from a YMCA of the USA impact report summary on Safety Around Water and Swim Instruction. Progress on providing sub-grants from the National Park Service to YMCAs to support underserved children was assessed via review of a final progress report that provided details on YMCA grantees and each of their projects, numbers of youth participants, and types of experiences. Progress on developing a Digital Storybook was obtained from grant reports. Progress on providing sub-grants to YMCA state alliances to advance active communities work was verified using a report prepared for Centers for Disease Control and Prevention summarizing all grantees and each of their activities, action plans, and capacity.
To verify progress on Hyatt’s commitment, calorie, sodium and total sugar averages were calculated for the top two selling a la carte items for breakfast, lunch and dinner from a random sample of 24 hotels of three-meal restaurants and in room dining. Calorie, sodium and total sugar values were averaged across the sample to monitor baseline values and annual changes throughout the commitment. Hyatt also provided three-meal restaurant and in-room dining menus to verify affordability and local procurement commitments.
To measure progress on the Mars Food U.S. commitments for 2017 and 2018, the Mars Food Nutrition Criteria, SKUs and sodium, added sugar and whole grain content were reviewed for existing and new products in the Mars U.S. Food product portfolio. The Uncle Ben’s online recipe database was examined along with nutrition analysis for all Everyday meal recipes available online. Additionally, a summary of Mars Foods media impressions, screenshots of the dotMars internal associate website providing recaps of employee education programs and photos of U.S. site cooking kitchens and fitness facilities were all reviewed. The menu from Mars Corporate Center Café was also reviewed to determine compliance with nutrition and affordability commitments for all U.S. site cafeterias.
The Hudson Institute Obesity Solutions Initiative (OSI) is serving as third-party validator of the National Confectioners Association’s Always a Treat commitment. In addition, Richard Black, PhD, Tufts University has provided input to the analytical methodology and examined the final conclusions and analyses.
For the 2016 benchmarking, IRI data for the 52 weeks ending December 25, 2016 were utilized to identify and analyze participating companies’ Instant Consumable candy and chocolate item sales (excluding gift items, gum and mints) according to two discreet categories: items that are ≤ 200 calories per pack, and those that are > 200 calories per pack. For the 2019 Midterm: IRI data for the 52 weeks ending June 16, 2019 based on the same guidelines used for the Benchmarking Report. For purposes of this study, Instant Consumables are defined as all candy and chocolate items (excluding gift packs, gum and mints) sold in packages ≤ 3.2 ounces (90 grams).
A tracking of whether calorie counts appear on the front of participating companies’ candy and chocolate items, except gift items, very small packages (< 12 sq. inches of total available label space), gum and mints, is being performed. Companies were requested to supply physical examples of packages by SKU to allow Hudson Institute to verify whether calorie information has been placed on front of pack (FOP). To cross-check the packaging information supplied by each company, the Hudson team has commissioned visual audits of confection products at retail checkout lanes in five cities for the Mid-Term evaluation.
PepsiCo’s progress towards meeting commitments to reduce added sugars in its beverage portfolio and reduce saturated fat and sodium in its foods portfolio were reviewed by an independent verifier during a meeting held at PepsiCo headquarters in Purchase, New York in September 2019. The verifier reviewed SKU-level data on beverages and foods sold in PepsiCo’s top 26 global beverage markets and top 23 global foods markets in 2018, as well as governance documents detailing the methodology used by PepsiCo to determine the total beverage and food volumes sold and nutritional information related to products sold, including definitions, assumptions, calculations, and rounding procedures. Product data and methods were reviewed for completeness against commitment guidelines agreed upon by PepsiCo and Partnership for a Healthier America, as well as publicly available information on PepsiCo products. Calculations were reviewed for accuracy and reproducibility using a random sample of beverage and food products from PepsiCo’s portfolio and publicly available data on nutrients in the selected products.
Progress on the commitment between PHA and Sesame Workshop and the Produce Marketing Association was assessed via review of data on suppliers and retailers who had submitted applications to use Sesame Workshop Assets to promote fruits and vegetables. Number of suppliers, retailers, and varieties of fresh fruits and vegetables were totaled and reported from tracking records.
Trinity Health’s progress towards meeting its commitment was assessed via review of a grant report that included grant award recipients and investments, amount of award, amount of cash match, date of award, length of award, and key activities to be completed. Number of grants and investments, total value of grants and investments, and total cash match were summed across all awards.
Shaping Early Palates
KinderCare Education’s commitments to serving one culturally diverse dish per week and at least two vegetarian entrees per week were verified using menu review. The verifier reviewed a pre-implementation five-week cycle menu from 2017 and a post-implementation four-week cycle menu from 2019 to assess menu offerings and changes. Development of curricula, training and onboarding materials, and family and center resources were verified by review of dated copies of all materials produced (and date distributed, where applicable) by KinderCare.
Learning Care Group’s commitments around whole grains were verified through a master grain and bread list from January 2019. Following the initial review of the chart in January 2019, Learning Care Group either found a new whole grain option for the few remaining options or removed them from the menu. The grain-based desserts were also verified from the master list of current grain options. The physical activity curriculum was verified through a copy of the curriculum, and the garden offerings were verified through recipe books from two menu cycles as well as from the seed offerings on Learning Care Groups internal shopping website.
To assess progress on Sprout commitments, verifiers reviewed product ingredient lists, nutrition facts panels and parent education campaign materials, videos and social media posts.
Shifting Retail Environments
Giant’s commitment to achieving stars on its private label brand products was verified by reviewing a list of all private label brand products and their associated star status. Products receiving 1, 2, or 3 stars through the Guiding Stars system were summed to determine total number of starred products. For front-of-pack labeling, a verifier randomly selected 75 products from Giant’s private label brand list and requested front-of-pack label proofs for these items. Of these, 55 products were excluded because they did not carry front-of-pack labels (e.g., bulk foods) or the labels were unavailable. For the 20 products with labels, a verifier reviewed front-of-pack label proofs to determine how many products had labels that included calories, saturated fat, sodium, and total sugars. Giant provided sales data for fruits and vegetables by quarter during the time the FNV campaign was activated at Giant stores to assess how sales were impacted by FNV as part of a broader produce marketing strategy.
Progress on commitments made by Vintner Distributers, Tri Star Energy, Ricker’s, Cumberland Farms, Aloha Petroleum, Enmarket, Kwik Trip and Maverick Inc. was determined by reviewing inventory reports, sales data and photos from stores to confirm that a minimum number of types of fruits, vegetables, whole grain products and low-fat dairy options were available. When applicable, verifiers reviewed store planograms and spreadsheets of products’ nutritional information to ensure stores offered a minimum number of products and grab and go items that met PHA’s definition of a Healthier Food and Beverage Product Criteria and to calculate linear feet of shelf space dedicated to fruits, vegetables, whole grains and low fat dairy. For healthier combo meals, verifiers reviewed recipes, nutritional information and store menus to ensure options are available that meet PHA’s Healthier Recipe Criteria. Verifiers reviewed employee handbooks and policies to confirm commitment elements around healthy employee benefits and access to bicycle racks.
To measure progress on food and beverage distributors, Core-Mark International, S. Abraham and Sons, Harold Levinson Associates, Harbor Wholesale Foods and the McLane Company provided lists of all products that meet PHA’s healthier food and beverage product criteria, sell sheets and access to or screen shots of online ordering websites and online mobile ordering applications. Companies provided planograms and merchandizers, nutrition information and recipes for private label products and examples of marketing including promotional product materials, web pages, web banners and social media posts for verification. Verifiers also reviewed policies, memos, newsletters and promotional materials on employee health and wellness activities and each company’s healthier food catering guides.
The National Association of Convenience Stores provided screen shots of its website outlining details of its PHA partnership, examples of resources developed to promote healthier products and practices and copies of emails to member companies encouraging engagement with PHA. Materials from its online community portal were provided to assess outreach and communication to National Corner Store Forum members on a variety of topics including community programs, partnerships, SNAP and WIC policy, store operations, product procurement and distribution, marketing and promotion.