By Arnell Hinkle

April 13, 2015

Tina Namian, Branch Chief
Policy and Program Development Branch, Child Nutrition Programs Food and Nutrition Service, Department of Agriculture
Post Office Box 66874 St. Louis, Missouri 63166

Docket ID: FNS-‐2011-‐0029

Step up the food quality in the Child and Adult Care Food Program!

Dear Ms Namian;

Thank you for the opportunity to provide comments on the 2015 proposed meal pattern for the Child and Adult Care Food Program (CACFP). The status of children’s health is declining with chronic diseases such as overweight and diabetes striking more and more children, especially those of low-‐income families. Improving the nutritional quality of snacks and meals available through CACFP is a critical step in reversing childhood disease trends. Therefore, I commend Secretary Vilsack and USDA for their efforts to improve the health and wellbeing of children participating in CACFP.

Communities, Adolescents, Nutrition, and Fitness (CANFIT), a national, non-‐profit organization, has been working since 1993 with communities and policymakers to develop culturally resonant policies and practices that improve food environments for adolescents in low income communities and communities of color. As part of its mission, CANFIT provides culturally-‐appropriate training and technical assistance to after school programs throughout the country. We have developed numerous materials to help youth providers implement healthy snack and meal programs.

As executive director of CANFIT, and co-‐chair of the Nutrition/Physical Activity Committee of the California Afterschool Network, I have had an opportunity to visit hundreds of after school programs. Based upon my experiences, I would like to focus my comments on community nutrition programs that serve adolescents, and request that FNS consider the following recommendations for improving the nutritional quality and availability of fresh, locally-‐sourced, sustainable foods in the CACFP.

Proposed Revisions

Overall, I applaud and support all of the proposed revisions, as they improve food and nutrition quality by aligning the meal pattern with the U.S. Dietary Guidelines. However, due to concerns associated with issues related to providing meals and snacks to adolescents in afterschool programs, I recommend the following:

- Implement the 13-‐18 year old group category, consider increasing the portion sizes to reflect increased caloric needs, and realize that additional funding will be needed to cover the costs.

- Allow providers to serve two vegetables for supper rather than mandating a fruit and vegetable. This will help increase the amount and variety of vegetables that youth consume.

- Adopt California’s Healthy Beverages in Child Care law by 1) limiting juice to one
age-‐appropriate serving of 100% juice per day; 2) ensuring that clean, safe drinking water is readily available throughout the day; 3) serving only fat-‐free or low-‐fat (1%) unsweetened, plain milk or an approved milk alternative; and 4) prohibiting beverages with added sweeteners, either natural or artificial.

- Clarify that the proposed requirement to serve one whole grain a day should be applicable only when a grain is served during the day. Afterschool programs serving only a snack might not have a grain component each day.

- That the words “recognizable” “customary” “usual” as applied to tofu be
reinterpreted in guidance language to include tofu soups and stews.

- Continue expanding the USDA Food Buying Guide to better align with cultural food preferences. I also recommend that USDA ask for a survey of state agencies and CACFP professional organizations to see what other fruits and vegetables could be included in the Buying Guide.

Best Practices

Fresh fruits and vegetables are the building blocks of healthy nutrition for children. It is a major step in nourishing healthy children and to reduce childhood overweight and the chronic illnesses that often develop when they are adults. Research shows that production methods for food (e.g., organic, less pesticides, etc) are important to children’s health. Production standards should be part of the standards set for food provided to our children similar to nutritional standards.

I think that the Best Practices that you have outlined are commendable, and recommend that they go even further by including the following:

- Provide at least 50% of foods produced without pesticides, chemicals, antibiotics and synthetic hormones.
- Ensure that at least 10% of fresh fruits and vegetables served as local/regionally produced.
- Align community nutrition program foods and menus with the cultural food patterns of participants.
- Provide higher reimbursement to community nutrition programs which meet higher nutrition standards.
- Provide incentives for increasing fresh fruits and vegetables in meals and snacks through Farm-to-Institution programs.
- Create incentives for switching from juice to fresh, whole fruits and vegetables.
- Provide funding for demonstration projects to improve food and beverage quality.
- Reduce frequency of juice service and increase frequency that fresh fruit and vegetables are provided.

Child nutrition programs that are focused on healthy, green, fair, and affordable foods are critical to nourish healthy children who will thrive. Therefore, I urge the USDA to bring the Child and Adult Care Food Program into the 21st century, and help it become a tool to reduce health disparities by making sure that low-income children are served whole foods that are healthy, produced in a sustainable manner, and are affordable.

Thank you for your consideration.

Sincerely,

Arnell Hinkle, RD, MPH, CHES
Executive Director,
CANFIT

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