Letter to USDA: Retired Admirals and Generals Urge Preservation of Healthy School Meals

February 27, 2020

Dear Secretary Perdue:

We are members of Mission: Readiness, the organization of over 750 retired admirals and generals working to mitigate and reverse the major health, educational, and behavioral barriers that prevent 71 percent of young Americans from being eligible to serve in uniform.

Today, excess body fat is the leading medical reason that the opportunities afforded by military service are out of reach for most young Americans. Military leaders have long believed that child nutrition is directly correlated with the strength of America’s future military readiness, and key to battling childhood obesity is the National School Lunch Program.

We are deeply concerned that the proposed rule, “Simplifying Meal Service and Monitoring Requirements in the National School Lunch and School Breakfast Programs” 85 FR 4094, dated January 23, 2020, would make several detrimental changes that could result in fewer vegetables, fruits and healthy grains served and consumed and effectively double the availability of unhealthy foods sold a la carte during the school week. We believe that the proposed rule is a direct challenge to the integrity of our nation’s school meals programs.

We understand that the USDA seeks to improve flexibility for school meal providers to reduce waste, and agree that children will not benefit from strong nutrition requirements if they are throwing a meal out without consuming it. The proposed course of action, however, does not remedy this challenge. We are greatly concerned that the proposed changes would further contribute to deeply concerning trends that show 90 percent of our children still do not consume enough vegetables, and two-thirds do not eat the recommended amount of fruits.

We urge the U.S. Department of Agriculture (USDA) to stay the course by building upon–-not retreating from–-efforts to make school meals healthier. Specifically, we ask USDA to withdraw three components of the proposed rule. We are concerned that:

1. The proposed increased availability of “competitive foods” - entrees sold a la carte - would allow children to regularly consume more sodium and saturated fats, and discourage the consumption of a balanced meal. When entrees are sold individually, students do not get the benefits of nutrients offered in a balanced meal. For example, students could buy multiple entrees; instead of purchasing a school lunch that contains a slice of pizza, carrots, fruit, and milk, a student could purchase three slices of pizza in the a la carte line, providing them with more calories and fewer nutrients. Under the current standards, whole grains must be the first ingredient in an entrée sold a la carte. This proposed rule removes that standard, potentially resulting in kids consuming more sodium and saturated fats.

2. The proposed rule would significantly reduce the research-informed amount and variety of vegetables consumed in schools. The proposed rule would move away from requirements encouraging children to consume a variety of healthy vegetables. It specifically reduces red/orange vegetable requirements to 0.5 cups for all age groups. With this reduction, programs may offer an increased amount of starchy and less nutrient-rich vegetables. While we applaud USDA’s emphasis on the tracking and reporting of legume consumption, the variety and amounts of each vegetable subgroup in accordance with age-based needs currently reflected in regulations was designed around a research-informed daily consumption of healthy vegetables, and should be maintained.

3. Reducing grain and fruit servings in school breakfasts would make the first meal of the day significantly less healthy. Providing for flexibility in local preferences while maintaining cost-effectiveness of serving school breakfasts outside the cafeteria is essential. However, we urge USDA to foster state innovations in offering/serving fruit in all breakfast settings and provide rule clarifications in how to meet grain requirements, rather than reducing the offerings of both. Furthermore, servings of fruit must not be allowed to be substituted by starchy vegetable servings. By reducing the fruit requirements for breakfasts and eliminating the minimum grain requirement, the result will be less healthful breakfasts. Participation in the School Breakfast Program is associated with increases in test scores and academic performance.

Seventy-five years ago, Major General Lewis Hershey, the Director of the Selective Service System, testified to Congress that at least 40 percent of World War II recruits were rejected for reasons related to poor nutrition. The following year, Congress established the National School Lunch Program as a “measure of national security to safeguard the health and well-being of the nation’s children.”

This tradition of school meals is rooted in innovation and local control. We wholeheartedly support the proposed rule’s intent to foster state innovations, reduce reporting redundancies and shore up the financial integrity of the program. However, we strongly urge the USDA to prioritize offering technical assistance to underperforming or out-of-compliance schools, rather than rolling back nutritional standards.

At a time when obesity is threatening the ability of the U.S. Armed Forces to find recruits healthy enough to serve, we are concerned that rolling back nutritional standards poses a direct threat to our national security.

American children receive up to half of their daily calories in school, and for some, it is their only access to regular and nutritious meals. As men and women who have served in the highest ranks of the U.S. Armed Forces, we have a deep and abiding interest in the pool of eligible recruits for future military service. However, we know that obesity is a serious public health crisis with impacts far beyond military readiness. Our national obesity epidemic is a threat to the future health, prosperity, and security of our nation.

We strongly urge USDA to maintain the existing nutrition standards and requirements for fruits and vegetables, and foster the consumption of balanced school meals by holding the line on availability of a la carte entrees. Doing so is critical to ensuring that America’s young people grow up healthy and prepared to succeed in the military or whatever career they choose.