To provide schools adequate time to train staff, secure necessary equipment, change menus, identify new suppliers, and help students adapt to the new meals, SNA advises delaying mandatory implementation of the rule until school year 2013-2014. The Association recommends incentivizing early implementation by providing the additional 6 cent reimbursement to schools that meet the new meal pattern prior to SY 2013-2014.
One major barrier to meeting the new standards is cost: USDA estimates that if the proposed rule is fully implemented, the cost of preparing a school lunch could rise by more than 15 cents while the cost of preparing a school breakfast could rise by more than 51 cents. Yet, the Healthy, Hunger-Free Kids Act provides only 6 cents more per lunch to help schools meet these new standards and no additional reimbursement to assist with costly improvements to breakfast.
In addition to purchasing more produce, whole grains and lean proteins, schools will face significant equipment and training expenses. Meeting the new requirements will require schools to secure additional coolers, freezers and dry storage spaces; upgrade small-wares and sinks required to wash and process the additional fresh produce; modify and replace serving lines to accommodate larger portions; and train staff on storage, preparation and service of new menu items.
These challenges arrive at a time when cash-strapped states are reconsidering financial support of school nutrition programs and when harsh winter conditions, world events and commodity shortages have driven food prices to historic heights.
In light of cost concerns, SNA recommends that implementation of the revised breakfast meal pattern requirements be delayed until additional funding is available to help offset costs. SNA also requests an easing of the new meat/meat alternate requirement for school breakfast, which could eliminate popular and healthy breakfast choices like whole grain pancakes or cereal.
Cost concerns also influenced SNA’s recommendation that the weekly requirement for legumes, dark green and orange vegetables be changed to encourage, rather than require, schools to vary vegetable selections (as is currently done in the HealthierUS School Challenge). SNA points out that rural areas and states such as Alaska face unique challenges to meeting these weekly requirements, such as dramatic price fluctuations for produce, variety and product availability during the winter months.
SNA also calls for easing the proposed rule’s severe limit on starchy vegetables, which include green peas, corn, lima beans and potatoes. The proposed rule hampers school efforts to offer locally grown vegetables throughout the fall and winter, as well as regionally preferred foods such as corn in Mexican dishes. The Association recommends allowing schools to offer more starchy vegetables each week, but suggests restricting the individual serving size of these vegetables to half a cup per meal and prohibiting deep-fried preparation.