Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Regulations Governing Nutritional Guidelines for Competitive Foods Sold in Virginia Public Schools [8 VAC 20 ‑ 740]
Action CH 740: To establish nutritional guidelines for all foods sold to students in the public schools during the regular school day
Stage Proposed
Comment Period Ended on 10/31/2013
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10/23/13  9:39 am
Commenter: Dr. Becky Domokos-Bays, RD SNS

Competitve Foods in Schools
 

Thank you for the opportunity to provide comments to the committee on the issue of competitive foods in schools.  I am the director for School Nutrition Programs in Alexandria City.  We are a nationally recognized program, a district of excellence in school nutrition and have schools who have been designated Healthier US School Challenge winners.  We have 13,600 students, approximately 60% qualifying for free and reduced price meals.    School nutrition has always had at its core the mission of providing healthy meals to students, and research continues to support that school meals are healthier than meals brought from home, and that students who eat school meals have healthier weights than those who do not.

There is a business side to school nutrition as well that must be recognized.  Our programs are expected to be self-sustaining, receving no school board operating funds.  We earn our way, paying for salaries, benefits, food, supplies, etc.  Some divisions pay indirect costs to support the general operating funds.  My program generates 69% of its revenue from federal funds, 3-4% from state funds (mandated federal match and breakfast incentive) and the remainder from contracts and cash sales.  Eleven (11%) percent of my revenue comes from a la carte sales. 

When the Healthy Hunger Free Kids Act (HHFKA) passed in December 2010, our programs encountered stringent new regulations that are still being implemented and some rules have not yet been released.  These regulations have increased the cost of doing business, and adding layers of complexity to an already complex program.  Food cost in Alexandria City rose to 43% of revenue, an increase of 4% over the prior three (3) years.   Labor and benefit costs (over which we have little control) also increased. 

Currently, the federal competitive foods regulations are set to be implemented in July 2014.  These rules mandate nutrition requirements of competitive foods and beverages for calories, fat and saturated fat, sugar and sodium and portion sizes.  There are also local wellness policies as mandated since 2006, that cover competitive food sales in schools.  If Virginia implements separate standards, our programs will potentially be regulated by 3 sets of standards for the same food and beverage items!  Imagine running a business in this manner. It is not a rational or finanically feasible option and does not help children.  I support the School Nutrition Association of Virginia's position that federal competitive foods regulations should govern school nutrition programs.

The committee can and should take great pride in the nutrition programs offered to Virginia's children.  There are thousands of dedicated, caring people working in our profession who care deeply and passionately about helping children be ready to learn and achieve, and who run efficient businesses that take no funds from the classroom.  Separate state standards are  not needed.  Thank you for this opportunity.

CommentID: 29152