In April 2024, the U.S. Department of Agriculture announced a new nutrition rule aiming to improve school meals. The rule builds upon the efforts of the 2010 Healthy, Hunger-Free Kids Act (HHFKA), which Michelle Obama championed as first lady, to improve school nutrition. That law was met with criticism, followed by attempts to roll back nutrition standards under the Trump administration and a relaxation of certain provisions by President Biden during the height of the COVID-19 pandemic.
The new rule, Child Nutrition Programs: Meal Patterns Consistent With the 2020-2025 Dietary Guidelines for Americans, will align the nutritional quality of public school meals served in schools nationwide more closely with the 2020-2025 Dietary Guidelines for Americans. However, it is important to note that several proposed provisions, initially released in February of 2023, were weakened after the USDA received feedback from food companies, school food professionals and more than 136,000 members of the public.
In my current work at Wellness in the Schools, a national nonprofit that works with school food providers to ensure access to nourishing food and active play for children in public schools, I’ve seen firsthand that nutrition guidelines are not just bureaucracy or a list to check, and can make a huge difference in the quality of school meals and learning outcomes. For these reasons, this new rule should be applauded.
However, there are several places where the rule could have gone further to make school meals more nutritious; it fails to cut chocolate milk from school cafeterias, for example and does not align its sodium reductions with the most recent dietary guidelines. Furthermore, not enough has been done to ensure that school food professionals have the budget, infrastructure and time to make these changes a reality — which, as we’ve seen in the past, can jeopardize buy-in from providers and long-term success.
The role of school meals in child nutrition
The USDA’s National School Lunch Program (NSLP) and School Breakfast Program (SBP) are fundamental federal nutrition assistance programs that provide low-cost or free meals and snacks to children in public and nonprofit private schools and residential childcare institutions. School meals are one of the healthiest food sources for many of the 29 million children participating in the NSLP, some of whom rely on school meals for more than half of their food intake. In 2023, school lunch and breakfast programs cost the federal government about $21 billion.
"29 million: The number of children who participate in the USDA's National School Lunch Program"
Since the Obama administration, continued efforts have been made to improve the nutritional profile of school meals to combat rising childhood obesity rates and nutrition insecurity. This new rule marks the next phase in this ongoing journey. In 2010, the HHFKA significantly improved school food and other child nutrition programs, by increasing whole grains, fruits and vegetables, and decreasing saturated fat and sodium to align with the 2010 version of USDA and U.S. Health and Human Services’ Dietary Guidelines. The act also required each local education agency participating in the NSLB and SBP to develop a local school wellness policy that promotes students’ health, well-being and ability to learn. Additionally, the HHFKA gave more funding to free and reduced-cost meals; gave additional funding to schools that met the updated required nutritional standards; and helped communities establish local farm-to-school networks and create school gardens, encouraging school districts to use more local foods in their cafeterias, a win for health as well as local farmers.
When the HHFKA became law in 2010, it had overwhelming support from Congress. A generation raised on Pizza Hut, Lunchables and microwave meals meant the average weight of children had increased significantly since 1980; 1 in 3 American children were now overweight or obese and rates of Type 2 diabetes and other diet-related diseases were increasing. However, when it came time to nail down specific rules and how they would impact certain players, the war against obesity and obesity-related illnesses turned into a war against former first lady Michelle Obama and others who had supported and championed the HHFKA.
Some Republican lawmakers began to criticize the HHFKA as a nanny-state intrusion by Mrs. Obama, arguing that parents know what their kids like best and schools should serve kids what they like. Food companies claimed that the new standards were too severe and would lead to excess food waste, and spent millions of dollars lobbying to thwart or change them. The School Nutrition Association (SNA), a national, nonprofit professional organization representing 50,000 members providing school food across the country, argued that some of the act’s requirements led to higher costs, food waste and reduced lunch participation.
The USDA rolled back some of the HHFKA’s standards in 2018, partly due to those same concerns. However, ample research suggests that none of these fears were substantiated.
Overall, nutrition advocates say that the HHFKA has been a public health success, with students consuming more fruits, vegetables and whole grains and fewer starchy vegetables. And research backs up these claims. A 2019 USDA study analyzed school meals to see if they were in accordance with nutrition regulations and found that school meals are significantly healthier — with lunches scoring 41 percent on the agency’s Healthy Eating Index, following the implementation of the HHFKA.
Given that the HHFKA was considered such an improvement, why is there a need to change school food nutrition guidelines again? The USDA’s new rule goes even further.
Key highlights of the rule
One of the most significant aspects of the rule is the establishment of limits on added sugars in school meals — the first limit of its kind, based on newer research about added sugar’s contribution to poor health outcomes like Type 2 diabetes as well as negative school behaviors and lower test scores. Beginning in the 2025-26 school year, breakfast cereals, yogurt and flavored milk will be subject to strict added sugar limits, meaning many manufacturers will have to make changes to products that are presently sold to schools. By the 2027-28 school year, cafeterias will be required to limit added sugars to fewer than 10 percent of calories across the week.
An interesting counterpoint on the inclusion of added sugars in the new rule came from a trade group, the Sugar Association, during deliberations about the rule. The group supported limits on added sugars but called applying limits to individual products like flavored dairy products “arbitrary,” cautioning that the new standards could inadvertently lead to increased use of artificial sweeteners. These additives are not addressed in the new rule but have their own health ramifications, highlighting a potentially significant oversight by the USDA.
Under the new rule, schools will now have more flexibility on many fronts. School meals can offer a wider range of meats and meat alternatives than previously allowed, including beans, yogurt, peas, lentils, eggs and tofu. Additionally, the previous grain requirement for schools is now more flexible and can be achieved with a combination of grains and protein, allowing for more diverse and nutritious choices for students.
Schools will be given more flexibility than before to substitute vegetables for fruits at breakfast. This will allow schools to serve more vegetables, which are generally lower in sugar and calories, and contain more vitamins, minerals, fiber, antioxidants and other nutrients than fruits.
Where the rule falls short
Under the new rule, schools have the flexibility to include more vegetables and meat alternatives. However, even better would have been requiring schools to include more vegetables and meat alternatives a certain number of meals per week. Making this change could lead to an increase in vegetable consumption and expose kids to more vegetables and meat alternatives in a school setting, a move that could lead to improved health outcomes and nutrition over the course of their lives. Research shows that it can take a child at least ten times to try a new food before they like it — an equity issue and an opportunity. For many children, school food is an occasion to try new things they don’t have the luxury of trying at home.
Despite many public health and nutrition advocates’ desire to eliminate flavored milk from school-provided meals, the USDA will continue to offer flavored fat-free and low-fat milk to students. However, as stated earlier, the new rule will introduce a limit on added sugar in flavored milk.
The new rule will require a 15 percent sodium reduction for lunch and a 10 percent reduction for breakfast by the 2027-28 school year. These changes will reduce student sodium consumption, which is linked to high blood pressure and heart disease, but does not do enough to align with the latest dietary guidelines. Furthermore, the rule maintains current sodium limits for the next three school years before gradually reducing sodium content — meaning the full impact of the change won’t be felt until many of today’s kids are out of school.
Beyond nutrition
The rule includes many other notable changes that go beyond what we might think of as “nutrition,” including making school meals more culturally inclusive. For example, schools serving primarily American Indian and Alaska Native children will be able to serve vegetables to meet the grain requirement, since the grain requirement is typically fulfilled with wheat, which is not a traditional Indigenous food.
Under the Buy American provision in the new rule, there will be a phased-in limit on the amount of non-domestic foods that school food authorities can purchase each school year, to support more resilient domestic regional food supply chains. This “geographic preference” for U.S. foods will encourage schools to incorporate more locally grown, raised and caught unprocessed food. However, it could have unintended consequences. Limiting the amount of food that can be procured internationally could make it more challenging to buy tropical fruits such as bananas, kiwi and pineapple, which are often kid-favorites, and certain spices, which are critical for increasing culturally inclusive meals.
Looking ahead towards a healthier future
Recognizing the importance of thoughtful implementation, which was a key point of contention during the rollout of the HHFKA, the USDA has opted for a gradual rollout of the new rule. While the rule goes into effect on July 1, 2024, program operators will have time to adjust; changes will not be mandated until the 2025-26 school year at the earliest. This phased approach ensures that schools have ample time to adapt their menus and operations to meet the new requirements seamlessly.
The implementation of the new rule will require additional assistance, training and funding for school districts to meet new targets. In my work, I have observed how critical side-by-side, hands-on training is to systemic change in public school cafeterias across New York City and recognize that further discussion is needed about how the USDA will support school districts in making these changes. The USDA’s Food and Nutrition Service recently announced $26 million in new grants to support the implementation of the updated nutrition standards. These grants are a good start. However, this is not enough funding to successfully implement the new rule. Much of the onus of implementation will now fall on the shoulders of school food providers — a missed opportunity by the federal government to ensure buy-in and an effective transition.
School meals are clearly a critical piece of childhood health. This is especially the case for vulnerable children who rely on them for the bulk of their nutritional intake. As policy on school meals continues to evolve, the USDA should keep in mind that these changes impact the children in our country suffering from food and nutrition insecurity the most and do what is necessary to ensure the transition happens in a way that is thoughtful and effective.
Alexina Cather is the director of policy and special projects for Wellness in the Schools, a national nonprofit that promotes healthy eating and fitness for kids in public schools.
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