1. Presentation of 2014 Position Paper

2. MEAL PATTERN FLEXIBILITY Retain the initial requirement that 50% of grains offered through school lunch and breakfast programs be whole grain rich. This action would ease declines in participation and provide reasonable flexibility. The 2010 Dietary Guidelines for Americans allows for the consumption of some refined grains.

3. SNA Members Recommend and Support the Availability of Whole Grain Bread and Grain Items for our Students

4. What Are Our Members Saying? Whole Grains are going well and kids are getting used to them. The main exceptions are Pasta, Tortillas and Whole Grain Breading's district-wide. Whole grain selections have worked with bakery items the best. Schools been successful at changing over cookies, waffles and some of the breakfast bread items. “White” whole grain buns and breads are accepted by students but brown-looking whole grains breads are not.

5. What Are Our Members Saying? Pasta entrees have historically been among student favorites however whole grain pasta has led to plate waste and in many districts a sharp decline in student participation on days when pasta entrees are served. Regional favorites such as grits and biscuits are wholesome affordable breakfast grains that when substituted with whole grain have had a negative impact on breakfast participation. Schools do not want to remove these items from menus next year! Going to 100% whole grain next year is expected to lead to further declines in student participation, increased costs, and plate waste.

6. How can we make Whole Grains work better for our schools?

7. MEAL PATTERN FLEXIBILITY Suspend the implementation of sodium Target 2 pending the availability of scientific research that supports the reduction in daily sodium intake for children. The Institute of Medicine (IOM’s) “School Meals: Building Blocks for Healthy Children” report commissioned by USDA, recommended assessing the progress and effects of sodium reductions on student participation rates, food cost, safety, and food service operations.

8. MEAL PATTERN FLEXIBILITY Remove the requirement that all students must select a ½ cup serving of a fruit or vegetable as part of a reimbursable breakfast and/or lunch. This requirement has led to increased program costs, plate waste, and a decline in student participation.

9. SNA Members Recommended and Support the Availability of Fruits and Vegetables for our Students

10. What Are Our Members Saying? Students are eating more fresh fruits than ever before and really seem to be enjoying them! Students now have access to a wider variety of vegetables than ever, and are beginning to accept them more readily Students eat more fruits and vegetables when they are colorful and appetizing.

11. What Are Our Members Saying? The cost to serve, store, and prepare the required portions and choices far exceeds the additional $.06 This requirement has led to increased program costs, plate waste, and, in some cases, a decline in student participation. The portion is too large for the younger children.

12. What do we Need to Make this Work Better for our Schools?

13. We need Flexibility around Implementation Remove the requirement that all students must select a ½ cup serving of a fruit or vegetable as part of a reimbursable breakfast and/or lunch. This requirement has led to increased program costs, plate waste, and a decline in student participation. OvS is a working and successful model. Our programs must remain fiscally solvent to allow us to keep nourishing our students

14. COMPETITIVE FOODS Reopen and extend the comment period on the “Smart Snacks in School” Interim Final Rule until July 2015. Extending the comment period would allow stakeholders at all levels (national, state, and local) to collect data to assess the impact of the rule during the first year of implementation and provide the USDA the opportunity to make reasonable, responsible, evidence-based adjustments to the final rule.

15. Possible Unintended Consequences Loss of sales/revenue Potential loss of meal participation o An increase in non-allowable foods brought from home vs. purchasing meals Fundraisers and other food sales: o Will directly compete for customers and revenue in the NSBP and/or NSLP (example: students purchasing beverages outside the NSLP) o These purchases may unintentionally contribute to excessive meal charges

16. Possible Unintended Consequences Increased costs due to: o Loss of inventory control due to mandated frequency of a la carte items o Pre-portioning condiments for a la carte sales o Making water available for afterschool snacks o Costs of R&D distributed to the end user

17. Possible Unintended Consequences Lack of availability and increased cost of: o Cheeses to meet these standards o Combination foods with ¼ cup of Fruit or Vegetable o Items that will meet the sodium standard and student acceptance of these items

18. Possible Unintended Consequences Confusion & frustration: o Among students – when is a food allowable or not (entrees and breads) o Among menu planners who are working with 3 sets of criteria – Alliance, HUSSC, and these new regulations Limitation on entrees is not consistent with the dietary guidelines or the premise of the HHFKA for menu planning by foods, not by nutrients. o School Administrators, parents, and the community o All CNS staff trying to accomplish these regulations

19. Summary We need to not only extend the comment period but also delay the implementation until such time as all stakeholders are prepared to successfully implement the standards. For vendors: adequate time for R&D; For schools: time for educating students, staff, parents, and the community; For operators: adequate time to properly procure foods and services and prepare staff for the changes.

20. STRENGTHENING SCHOOL MEAL PROGRAMS Encourage a clear and coordinated strategy between the USDA and the US Department of Education to achieve a school environment supporting students’ health, well-being, and academic success. Collaboration between USDA and USDE to add nutrition education to the Core curriculum in Math, Science, History and Geography.

21. STRENGTHENING SCHOOL MEAL PROGRAMS Building and reinforcing the connection back to the Cafes. Develop marketing tools that emphasize the collaboration between academic achievement and nutrition programs. Who should we talk to encourage this partnership?

22. Joint efforts are essential to address adequate time for students to consume meals and for the development of curriculum that supports a healthy school environment. Explore options such as Recess before lunch; Breakfast on the Go; breakfast in the classroom. STRENGTHENING SCHOOL MEAL PROGRAMS

23. Increase awareness that more time is needed for students to consume meals. Using research (e.g. Minnesota Study) to emphasize the importance of readiness for learning. Challenges such as added cost to extend the school day. Contractual restraints. Do you have examples you can share that work? STRENGTHENING SCHOOL MEAL PROGRAMS

24. Return to the five year administrative review cycle. State agencies overseeing school meal programs do not have adequate staff and resources to effectively sustain the new three year administrative review cycle under the HHFKA. Returning to the five year administrative review cycle would allow state agencies to provide School Food Authorities (SFAs) greater support and guidance as they work to meet new standards.

25. STRENGTHENING SCHOOL MEAL PROGRAMS Address problem of unpaid meal charges. Unpaid meal charges by students continue to increase. The USDA should fully implement the requirements of the HHFKA to examine and report on this issue and then implement regulations that effectively address debt arising from unpaid meal charges.

26. STRENGTHENING SCHOOL MEAL PROGRAMS Provide flexibility on Paid Meal Equity. Section 205 of the HHFKA mandates that SFAs increase their paid meal prices regardless of their financial solvency. Congress should allow local flexibility by narrowing Section 205 to include only those SFAs that have a negative fund balance at the end of the previous school year.

27. STRENGTHENING SCHOOL MEAL PROGRAMS Increase program simplification. As Congress drafts and the USDA implements the 2015 Child Nutrition Reauthorization, efforts should be made to simplify child nutrition programs, easing the administrative and paperwork burdens on SFAs.

29. Questions?