Action Alerts

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Action Alerts

Below you will find actions that you can take at the federal, state, and local level. Help make a difference and get involved. In addition to legislative action, you can Create Change in your own local school district. Your voice does matter, and you can make a difference!

 

Federal

 Action Alert: 

USDA School Nutrition Standards – Deadline to Comment – this Wednesday, May 10

The USDA has proposed updates to the School Nutrition Standards. You can see a comparison chart of the current versus proposed rules here.

Submit your comments here. (Click on the “Comment” Button near the top left)

You will have the biggest impact if you use your own words. The USDA is asking for two things: 1. They want to know what we like (ie, “Maintain”), and 2. They want to know what other improvements could be made (ie. “Update”). These are the points we are encouraging our supporters to make:

Maintain:

  • Change the name of the meat/meat alternate component to “protein” or “protein component”.
  • Limit added sugars
  • Ban flavored milk in ALL grades K-12. (they are asking if flavored milk should be banned in K-8)
  • Offer non-dairy milk without the need for a parent/caregiver or doctors note.
  • Remove the stringent guidelines for non-dairy milks that require it to be nutritionally equivalent in many nutrients to cow’s milk. Cow’s milk is not a healthy standard.
  • Stop using the term “Whole-Grain Rich”.
  • Make 80% of the grains actually whole grain (as opposed to 80% whole grain rich which means 40% whole grain).
  • Implement the proposed sodium reductions.
  • Allow starchy vegetables to count as the grain requirement in all schools, not only tribally operated schools.
  • Explicitly state that traditional foods can be served as part of a reimbursable meal (it’s already allowed, the USDA plans to add a specific statement).
  • Allow Nuts & Seeds to count toward 100% of the Meat/Meat Alternate requirement.
  • Add hummus to the list of foods that are exempt from the total fat standard in the Smart Snack Regulations. This refers to snacks and not to hummus served during a meal.
  • Allow locally grown food to be used as a procurement specification.

Update:

  • Prevent the use of artificial sweeteners in place of added sugars.
  • Modify the Serve model for middle and elementary schools such that milk is always an optional meal component, even when a school is NOT participating in Offer versus Serve.  
  • Clarify that SFAs are authorized and encouraged to provide a non-dairy beverage that meets the USDA standards to any student with a special medical or dietary need whose parent or guardian makes a request. 
  • Clarify that plant-based diets can qualify as a special medical or dietary need, whether the diet is due to religious, cultural, physiological, ethical, or other reasons.
  • Clarify that lactose intolerance can be considered both a disability and a special medical or dietary need. 
  • Provide a model parental notice and form for milk substitution requests that SFAs can use on their websites and mail to families. 
  • Allow additional healthcare professionals to write a note to support meal modifications that do not meet the meal pattern requirements.
  • Amend regulations and policy memoranda for all school meal programs other than the NSLP such that disability-related substitutions must be made available upon request of a parent or legal guardian.
  • Eliminate access to flavored milk and facilitate access to non-dairy substitutes instead.
  • Require that all grains in school meals be whole grain-rich; or adopt a minimum fiber standard of 14 grams per 1,000 kilocalories per day. We feel that the term “whole grain rich” is very confusing and request that USDA stop using that term and uses a percentage instead.
  • Ban processed meats from schools, because they are a “known human carcinogen”, according to the World Health Organization.
  • Expand the option to serve starchy vegetables to meet the grains component to include all schools since Native Samoan, Puerto Rican, Virgin Islander, Guamanian, Hawaiian, African Americans, Asian Americans, and Latin Americans children live throughout the mainland U.S. and not just in certain territories, reservations, or locations where these populations may be concentrated.
  • Expand the list of allowable vegetables to substitute for grains to include winter squash, sweet potatoes, cassava (yuca), and taro, in addition to USDA’s proposal to add prairie turnips.
  • Require vegetables allowed to be substituted for the grains component to be prepared in ways that align with traditional cultural preparations.
  • Consider and support additional populations for whom standard school meals are not reflective of their traditions and cultures.
  • Align the nutritional equivalency Food and Nutrition Services has set for nuts and seeds in schools – as well as nut and seed butters – with the Dietary Guidelines for Americans. For example, this would result in 2 Tablespoons of nut butters to count as a 2 ounce M/MA equivalent, rather than the 4 Tablespoons currently required.
  • Include quinoa and other grains high in protein in the new “protein sources” meal component.
  • Encourage schools to offer daily plant-based options beyond a nut butter sandwich or hummus.
  • Allow beans, peas, and lentils – as well as tofu and soy products – to qualify as a meat alternate even if they are not visually recognizable.
  • Allow pastas made from legumes, such as red lentil, black bean, or chickpea pasta, to credit as a meat alternate regardless of whether it is served alongside a visually recognizable meat/meat alternate, and allow beans, peas, and lentils to credit as a meat alternate in smoothies.
  • Clarify that beans, peas, and lentils can credit as both a vegetable and meat alternate on the same day if served in sufficient quantities.
  • Allow a single legume dish to credit as a vegetable or meat alternate on the same day.

Below are more details. Beyond that, you will find a section to cut and paste but to submit this you would need to put it in a document and upload it as an attachment because it exceeds the character limit of the comment field. We recommend that you use your own words as those have much more impact.

Summary:

  • Added sugars – we’ve seen school breakfasts with more than 50 grams of added sugars.
    • Please support the limitations on added sugars.
  • Milk – the USDA is asking for input on two options – 1. Unflavored milk only for grades K-5 or K-8, OR 2. Flavored milk allowed in all grades. The added sugar limit would apply to flavored milks. This is what we are asking for and hope you will join us in making these requests:
    • Ask the USDA to ban flavored milk in ALL grades K-12.
    • Ask the USDA to offer non-dairy milk without the need for a parent/caregiver or doctors note.
    • Remove the stringent guidelines for non-dairy milks that require it to be nutritionally equivalent in many nutrients to cow’s milk. Cow’s milk is not a healthy standard.
  • Grains – the USDA is asking for input on two options – 1. Keep the current standard which is that 80% of the grains need to be “whole-grain rich” which actually means 40% of the grains need to be whole grain. (Whole Grain Rich is an industry term to make their products look healthier than they really are – if you want to know what percentage of a product is actually whole grain, divide the whole grain rich number in half) or 2. Require 100% of grains to be “whole-grain rich” which actually means that 50% of the grains would be whole grain.
    • Ask the USDA to stop using the term “Whole-Grain Rich”.
    • Ask the USDA to make 80% of the grains actually whole grain (as opposed to 80% whole grain rich which means 40% whole grain).
    • Allow starchy vegetables to count as a whole grain, such as: sweet potatoes, potatoes (not deep fried), winter squash, taro, cassava, and others, as this also addresses equity by being able to offer culturally appropriate foods.
  • Sodium – The USDA is asking for 2 reductions for sodium for breakfasts by 10% each time in 2025-2026 and again in 2027-2028 and 3 reductions in sodium by 10% each for lunches in the years 2025-2026, 2027-2028, and 2029-2030. In 2010 new regulations were made for sodium with three reduction periods which were supposed to be complete in 2023. These new regulations do not go as far as the original reductions, but get school meals back on track to have less sodium.
    • Ask the USDA to implement the new proposed sodium limits.
  • Menu Planning Options for American Indian and Alaska Native Students – The USDA would like to allow vegetables to meet the grain requirement in tribally operated schools.
    • Ask the USDA to allow starchy vegetables to count as the grain requirement in all schools, not only tribally operated schools.
  • Traditional Foods – The USDA would like to explicitly state that traditional foods can be served as part of a reimbursable meal.
    • Ask the USDA to explicitly state that traditional foods can be served as part of a reimbursable meal.
  • Nuts & Seeds – The USDA would like to allow nuts and seeds to count toward 100% of the “Meat/Meat Alternate (M/MA)” requirement. This is good because previously, given a two-ounce M/MA requirement, schools could serve a 1-ounce bag of sunflower seeds, for example, but then needed a 1-ounce equivalent of some other food that qualifies as a M/MA, for example legumes, cheese, or meat, and most of the time it wasn’t legumes!
    • Ask the USDA to allow Nuts & Seeds to count toward 100% of the M/MA requirement.
    • Ask the USDA to modify the one-ounce equivalent for nut butters. Currently, a one-ounce equivalent of nut butter is two tablespoons. That makes a two-ounce equivalent is four tablespoons. That is too much, and results in waste. Ask the USDA to make the nut butter 1-ounce equivalent 1 tablespoon, so that the required two-ounce equivalent is two Tablespoons which is a standard serving size and therefore in alignment with the US Dietary Guidelines, which the school meal program is supposed to reflect.
  • Competitive Foods Hummus Exemption – Adds hummus to the list of foods that are exempt from the total fat standard in the Smart Snack Regulations.
    • Ask the USDA to add hummus to the list of foods that are exempt from the total fat standard in the Smart Snack Regulations. This refers to snacks and not to hummus served during a meal.
  • Geographic Preference Expansion – Allows locally grown food to be used as procurement specification to make it easier to purchase local foods.
    • Ask the USDA to allow locally grown food to be used as a procurement specification.
  • Change the name of the meat/meat alternate component to “protein” or “protein component”.

 

Cut & Paste Section for Comments

(or use your own words but it is helpful for the USDA for you to references the sections to make sure your comments are tallied correctly)

Maintain in the Final Rule

Some of Coalition for Healthy School Food’s priorities are included in the Proposed Rule, and we express our advanced appreciation for maintaining these in the Final Rule:

Section 2: Limit added sugars in school meals and CACFP.

  • Product-based limits: Beginning in SY 2025-2026, this rulemaking proposes to implement quantitative limits for leading sources of added sugars in school meals, including grain-based desserts, breakfast cereals, yogurts, and flavored milks.
  • Weekly dietary limit: Beginning in SY 2027-2028, this rulemaking proposes to implement a dietary specification limiting added sugars to less than 10 percent of calories per week in the school lunch and breakfast programs; this weekly limit would be in addition to the product-based limits described above.

Section 6: Menu Planning Options for American Indian and Alaska Native Students

  • Expand the option to serve vegetables to meet the grains component to include the Child and Adult Care Food Program and Summer Food Service Program. (Specifically, starchy vegetables)
  • Expand the option to serve vegetables to meet the grains component to include all schools. (Specifically starchy vegetables)

Section 7: Traditional Foods

  • Explicitly state in regulation that traditional foods may be served in reimbursable school meals.
  • Commit to supporting efforts to incorporate traditional foods into school meals, including by addressing barriers to doing so.

Section 10. Nuts and Seeds

  • Allow nuts and seeds to credit for 100 percent of the meat/meat alternate component in all child nutrition programs and meals.

Section 11. Competitive Foods – Hummus Exemption

  • Add hummus to the list of foods exempt from the total fat standard in the regulations, which will allow hummus to be sold as a Smart Snack.

Section 15: Miscellaneous Changes

  • Change the name of the meat/meat alternate component to “protein” or “protein component”.

Section 17. Proposals from Prior USDA Rulemaking

  • Allow legumes offered as a meat alternate to count toward the weekly legume vegetable requirement. 

 

Update in the Final Rule

I am also asking the USDA to strengthen the Final Rule as follows: 

Section 2: Prevent product reformulations that use artificial sweeteners in place of added sugars.

  • The health effects of artificial sweeteners are not known, and due to new rules, I’d like to be sure that companies that supply food to schools do not substitute artificial sweeteners for sugar.

Section 3: Milk

  • Modify the Serve model for middle and elementary schools such that milk is always an optional meal component, even when a school is NOT participating in Offer versus Serve.  
  • Clarify that SFAs are authorized and encouraged to provide a non-dairy beverage that meets the USDA standards to any student with a special medical or dietary need whose parent or guardian makes a request. 
  • Clarify that plant-based diets can qualify as a special medical or dietary need, whether the diet is due to religious, cultural, physiological, ethical, or other reasons.
  • Clarify that lactose intolerance can be considered both a disability and a special medical or dietary need. 
  • Provide a model parental notice and form for milk substitution requests that SFAs can use on their websites and mail to families. 
  • Allow additional healthcare professionals to write a note to support meal modifications that do not meet the meal pattern requirements.
  • Amend regulations and policy memoranda for all school meal programs other than the NSLP such that disability-related substitutions must be made available upon request of a parent or legal guardian.
  • Eliminate access to flavored milk and facilitate access to non-dairy substitutes instead.

Section 4: Whole Grains

  • Require that all grains in school meals be whole grain-rich; or adopt a minimum fiber standard of 14 grams per 1,000 kilocalories per day.
  • We feel that the term “whole grain rich” is very confusing and request that USDA stop using that term and uses a percentage instead, such as 50% whole grain, which would mean the same thing as 100% whole grain rich. We believe the requirement should be more than 50% whole grain, and that’s not really possible when saying 100% whole grain rich. Since we want students eating more fiber and more whole grains, it’s important that terminology used is not confusing to the staff who plans their meals or to individuals who may hear that term. 

Section 5: Sodium 

  • Encourage schools to prioritize reductions in sodium via eliminating processed meats.

Section 6: Menu Planning Options for American Indian and Alaska Native Students

  • Expand the option to serve starchy vegetables to meet the grains component to include all schools since Native Samoan, Puerto Rican, Virgin Islander, Guamaniam, Hawaiian, African Americans, Asian Americans, and Latin Americans children live throughout the mainland U.S. and not just in certain territories, reservations, or locations where these populations may be concentrated.
  • Expand the list of allowable vegetables to substitute for grains to include winter squash, sweet potatoes, cassava (yuca), and taro, in addition to USDA’s proposal to add prairie turnips.  
  • Require vegetables allowed to be substituted for the grains component to be prepared in ways that align with traditional cultural preparations.

Section 7: Traditional Foods

  • Consider and support additional populations for whom standard school meals are not reflective of their traditions and cultures.

Section 10. Nuts and Seeds

  • Align the nutritional equivalency FNS has set for nuts and seeds – as well as nut and seed butters – with the DGA. For example, this would result in 2 Tablespoons of nut butters to count as a 2 ounce M/MA equivalent, rather than the 4 Tablespoons currently required. 

Section 15: Miscellaneous Changes

  • Include quinoa and other grains high in protein in the new “protein sources” meal component. 
  • Eliminate processed meats. The World Health Organization has determined that processed meats, such as deli slices, sausage, bacon, hot dogs, pepperoni are “known human carcinogens”. We do not feel that “known human carcinogens” have any place in school meals. 
  • Encourage schools to offer daily plant-based options beyond a nut butter sandwich or hummus.
  • Allow beans, peas, and lentils – as well as tofu and soy products – to qualify as a meat alternate even if they are not visually recognizable.
  • Allow pastas made from legumes, such as red lentil, black bean, or chickpea pasta, to credit as a meat alternate regardless of whether it is served alongside a visually recognizable meat/meat alternate, and allow beans, peas, and lentils to credit as a meat alternate in smoothies. 
  • Clarify that beans, peas, and lentils can credit as both a vegetable and meat alternate on the same day if served in sufficient quantities. 
  • Allow a single legume dish to credit as a vegetable or meat alternate on the same day.

Additionally, across all of the changes made to the meal patterns, we urge USDA to do everything possible to best support the child nutrition program professionals leading implementation of the changes. Comprehensive training and technical assistance and streamlining the regulations across the myriad programs will support the changes so that they can be successful. CNP professionals will be able to invest less of their time in navigating needed menu planning differences across various programs and more time into achieving the new standards, all with support from USDA.

*** This concludes the cut and paste section ***

 

Universal Free Meals

The Universal School Meals Program Act of 2021 (S. 1530 / H.R. 3115), introduced by Senators Bernie Sanders (VT) and Kirsten Gillibrand (NY) and Representatives Ilhan Omar (MN) and Gwen Moore (WI), would ensure that every child has access to free meals at school, after school and during the summer, regardless of income. This critical program would reduce childhood hunger, enhance school readiness among children, and strengthen local economies by incentivizing local food procurement. The bill did not pass and become law. Please call your Congressional Representative today to voice your support for Universal Free Meals. During the first few years of the pandemic, all US public schools had Universal Free Meals, but that stopped in June of 2022. Some states have enacted Universal Free Meals bills, including California, Colorado and Maine. Massachusetts, Nevada, and Vermont have Universal Free Meals for the 2022 – 2023 school year. 

US Dietary Guidelines: (More Coming Soon)

The US Dietary Guidelines are updated every five years. They are the public food policy for the United States and are the basis of nutrition education in schools and other places, and of food served in schools, hospitals, nursing homes, and other institutions. Learn more about the Guidelines and the process here, and we’ll be back with recommendations for written comments, and share with you how to make comments.

 

State

New York State: S996/ A3708

Relates to requiring public schools to offer plant-based food options in food service

Bill in New York State introduced by League of Humane Voters of New York that would require schools to provide a plant-based meal at the request of students or persons in parental relation to students. Elected officials are concerned that it would cost more but schools tell us that plant-based meals cost less or are at least cost-neutral. In New York City, the food cost for the vegetarian menu, at least at a point in the past, is 9 cents less than the standard menu. In Ithaca, the cost is cost-neutral. Based on the cost of the various menus in New York City, if they switched all schools to vegetarian menus, they could save over $10 million dollars per year. We are actively working in partnership with Physicians Committee for Responsible Medicine (PCRM) to advocate for the bill. Please contact (this link will take you to an easy PCRM form to fill out) your New York State Senator and Assemblyperson now and urge them to pass this law. Click on the bill numbers above to read the bills. If you are a school district, a Food Service Director, or a business that would be positively impacted by this bill (for example, bean farmers), you can sign on to a letter to show your support. If you would like us to send you that letter for your review, please email us. The state of Illinois recently passed a similar bill. 

 

S4311 / A959

Relates to prohibiting the operation of establishments where animals and/or fowls are slaughtered and butchered for food.

Bill in New York State that would suspend the operation of live animal markets and create a task force on the public health risks and animal welfare concerns of slaughterhouses.  Currently, the bill is in the Senate and Assembly Committees on Agriculture. The purpose of the proposed law is to eliminate live animal markets, a potential breeding ground for the transmission of zoonotic diseases. Many of these poorly regulated markets operate in close proximity to schools, homes and parks. These establishments have been issued violations by the New York State Department of Agriculture and Markets for offenses including leaving animal blood and feces on public sidewalks, allowing grime to accumulate on butchering equipment, and other unsanitary conditions.

Not only are these markets cruel to the animals killed there (chickens, ducks, goats, sheep, cows and others), but they are hazardous to the health of the employees that work there and the customers who frequent them. Please let your legislators know your support the passage of this important legislation.

For both state bills:

Find your NY Senator’s email address here: https://www.nysenate.gov/find-my-senator

Find your NY Assembly Member’s email address here: https://nyassembly.gov/mem

 

Local 

There probably won’t be local laws passed to change the food in your local district, but that doesn’t mean you can’t make a difference and effect change. It’s important to be strategic in approaching a local school, for example should you approach the food service director, the superintendent, a school board member, or a principal? It’s important to do your research and know something about the person you are going to reach out to. If the food service director has a history of being resistant to change, then starting with that person might not be the best choice (though we find most food service directors open to change, not all are). New York City works quite differently from many other school districts, so speaking with the mayor’s office, the borough president’s office, or your local council member could make a difference. What can you ask local schools to do? Check out our Create Change section.