The Healthi Kids Coalition supports the current school food standards in the Healthy Hunger-Free Kids Act, the coalition wrote to USDA’s Division of the Food and Nutrition Service.

A work group of local food leaders drafted the letter. It responds to proposed changes to school food rules for milk, whole grains and sodium. The coalition noted that the current standards give all kids access to high quality and nutritious meals. It pointed out that the current rules may promote better health.

The coalition shared programs in Rochester schools that have led kids to eat more fruits and vegetables and waste less food. These innovations include salad bars, low-sodium flavor stations, food-service worker training and youth food councils. The text of the letter is posted below.

To get involved, contact Jenn Beideman at 585-224-3151 or

Monday, January 29, 2018

Tina Namian, Chief
School Programs Branch, Policy & Program Development Division
Food and Nutrition Service
3101 Park Center Drive, 12th Floor, Alexandria, Virginia 22302

Re: Child Nutrition Program Flexibilities for Milk, Whole Grains and Sodium Requirements

Dear Ms. Namian,
On behalf of the Healthi Kids Coalition, an initiative of Common Ground Health, we welcome an opportunity to comment on the Department of Agriculture’s (USDA) interim final rule: Child Nutrition Programs: Flexibilities for Milk, Whole Grains and Sodium.  The Healthi Kids Coalition is a grassroots community coalition of over 460 volunteers and community organizations. Our coalition is comprised of pediatricians, child care providers, registered dietitians, healthcare professionals, the local food bank, local nonprofit groups, residents and parents who advocate for healthier, more active kids in Monroe County, New York. 

Studies from the Center on the Developing Child at Harvard University and the U.S. Centers for Disease Control and Prevention demonstrates that good nutrition is the foundation for learning and children’s optimal growth and development. The NSLP makes it possible for children across the country to receive healthy meals at school every day.  For the last ten years, the Healthi Kids Coalition has been working with the Rochester City School District (RCSD) to advance healthier school meals.  The Healthi Kids Coalition strongly supports maintaining the current, evidence-based nutrition standards as set through the Healthy Hunger-Free Kids Act (HHFKA).

Current school meal standards improve food security in the City of Rochester: 

The Healthi Kids Coalition strongly supports the current nutrition standards as identified in the HHFKA to ensure all kids, regardless of income, have access to high quality and nutritious meals. Studies indicate food insecurity has a negative impact on children’s physical, social-emotional and cognitive development, and inhibits a child’s ability to learn.  In the City of Rochester, the rate of childhood poverty is alarming: 
• Over 50 percent of children in the City of Rochester live in poverty
• 83 percent of children are eligible for free or reduced-price lunches

Often the only meals students have throughout the week are during school hours through federal meal programs. It is critical the meals provided to our students continue to be healthy and consistent with the Dietary Guidelines for Americans and the American Heart Association guidelines that include reducing sodium, added sugar and eating 100 percent whole grain rich foods.

As one of the primary sources of nutrition for millions of children, federal school meal programs should seek every opportunity to limit added sugars. Children should be encouraged to choose healthy beverages including low-fat milk without added sugar and water.
Current school meal standards improve health outcomes: 

Ensuring healthier school meal standards in schools across the country is critical. The Healthi Kids Coalition is concerned the proposed changes in the interim final rule will impact the overall progress made to reduce childhood obesity across the country. Research from the American Academy of Pediatrics indicates childhood obesity is responsible for $14 billion in direct medical costs. In the City of Rochester, childhood overweight and obesity have emerged as a public health crisis:

• 1 in 3 children are overweight or obese
• 38.2 percent for African American children; 46.6 percent for Latino children; and 37.7 percent for Caucasian children

Student participation in school meals programs reduces poor health outcomes, obesity and food insecurity.  To reduce the long term economic impact of childhood obesity, it is critical schools continue to serve high quality, nutritious meals to children. Research from the PEW Charitable Trusts shows that the standards set by the HHFKA are improving overall nutrition habits, and students of all ages are choosing more nutritious lunches and consuming more of their entrees. 

These results echo local research conducted by Healthi Kids and Children’s Institute that analyzed student preference and waste of school meals in the RCSD:  
• 68 percent of students eat most of their entrees at lunch
• 76 percent of students drank all or most of their milk
• 77 percent of children consumed their selected fruit

The current school meal standards are providing a supportive environment for children and are leading to improved dietary habits and positive attitudes towards eating healthy and exercise. 

The current school meal standards work:

The current nutrition standards set in the HHFKA work. Since 2012, the Rochester City School District has continued to successfully meet and exceed current nutrition requirements. Our local research demonstrates the current standards are effective: 
• Two-thirds of all students surveyed indicated they enjoyed the food served
• 50 percent of students shared they would like more variety in their meals, healthier choices, and additional vegetables and fruit options
• 23 percent of children identified they would like more fruits and vegetables
• 22 percent of children identified they would like additional seasoning and fresher quality ingredients

To meet the current standards RCSD and the Healthi Kids Coalition have piloted many successful, low-cost and innovative programs including: 
• Salad bars and flavor stations that permit kids to customize their meal with low sodium flavor options
• Improving marketing of healthier options
• Establishing youth and teen school food advisory councils
• Training food service professionals

In the future we will continue to work alongside our local district to pilot these and other initiatives like Farm to School that enhance school meal quality. School districts across the country can replicate the success of the RCSD Food and Nutrition Service to meet the current HHFKA standards. 

The flexibilities provided in the interim rule threaten the progress that has been made to date. Every child, regardless of their socioeconomic status, deserves nutritious school meals that support their ability to reach their highest potential. The Healthi Kids Coalition strongly encourages the USDA to fully implement the HHFKA standards in its final rule. It hurts our children and our entire community to continue rolling back the requirements.

Thank you for this opportunity to comment on the interim final rule. If you require any additional information please contact Jenn Beideman at or 585-224-3151.

Dina Faticone, Director of Community Health & Engagement
Common Ground Health